Investor Charter

In Respect of Investment Adviser M/s Ventugrow Consultants Private Limited.

SEBI registration number INA000013235 and BASL1560

1. Vision and Mission Statements for Investors

   Vision

   Emotionless Investing.

   Mission

   Every investor should be able to invest in suitable investment products based on their needs, manage and monitor investments to meet financial goals, access relevant reports, and enjoy financial well-being.

2. Details of Business Transacted by the Investment Adviser with Investors

   The Investment Adviser provides investment-advisory services in accordance with the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013, as amended from time to time (“IA Regulations”).

   The IA shall, among other things:

   • Provide investment advice after undertaking appropriate client profiling and risk-profiling.
   • Obtain sufficient information regarding the client’s financial position, investment objectives, investment horizon, risk appetite, existing investments and other relevant circumstances.
   • Assess suitability before providing investment advice or recommending securities/investment products.
   • Enter into a written agreement with the client, containing the required terms and conditions, before rendering investment-advisory services.
   • Charge fees only in the manner permitted under applicable SEBI regulations and circulars.
   • Maintain records of client information, risk profiling, suitability assessment, advice/recommendations, fee arrangements and other records as required under the IA Regulations.
   • Make disclosures regarding conflicts of interest, material facts and any other information required under applicable law.
   • Maintain confidentiality of client information, except where disclosure is required under applicable law, regulation, court order or regulatory direction.
   • Not guarantee, assure or promise any return, profit or performance in respect of securities or investment products.
   • Not receive any consideration, directly or indirectly, from issuers, intermediaries or other persons in a manner prohibited under applicable SEBI regulations.

   The precise scope of services, exclusions, frequency of interaction, mode of delivery of advice, fee arrangement and termination rights shall be governed by the executed client agreement.

3. Details of Services Provided to Investors

   The services offered by the Investment Adviser may include, subject to the IA’s SEBI registration, client agreement and applicable regulatory permissions:

   • Personalised investment advice based on the client’s financial profile, objectives, investment horizon and risk appetite.
   • Financial-planning-related advice, including goal-based investment planning.
   • Advice in relation to securities and investment products permitted under the IA Regulations.
   • Asset-allocation guidance and portfolio-related recommendations.
   • Periodic review of advice or portfolio, where agreed in the client agreement.
   • Recommendations relating to purchase, sale, holding or dealing in securities, subject to the terms of engagement.

   The Investment Adviser shall clearly communicate whether any service is:

   • Comprehensive investment advice;
   • Limited or product-specific investment advice;
   • Financial planning advice;
   • Periodic review or monitoring service; or
   • Any other advisory service permitted under applicable law.

   The Investment Adviser shall not provide services outside the scope of its SEBI registration or in breach of applicable regulatory restrictions.

4. Rights of Investors

   An investor/client is entitled to:

   • Deal with a validly registered SEBI Investment Adviser.
   • Verify the IA’s registration details, including its SEBI registration number and registration status.
   • Receive investment advice suited to the client’s financial situation, investment objectives, risk appetite and investment horizon.
   • Receive a copy of the duly executed investment-advisory agreement.
   • Obtain clear disclosure of the scope of services, terms of engagement, fee structure, refund policy, termination process, risks and material conflicts of interest.
   • Receive advice that is based on adequate and appropriate client profiling and suitability assessment.
   • Know the basis, rationale, risks, assumptions and limitations associated with an investment recommendation.
   • Seek clarification regarding advice, fees, products, risks, conflicts of interest or any other aspect of the advisory engagement.
   • Be informed of actual or potential conflicts of interest that may affect the objectivity of advice.
   • Receive confidentiality and appropriate protection of personal and financial information.
   • Receive fair, ethical and professional treatment from the Investment Adviser.
   • Lodge complaints with the Investment Adviser and obtain information regarding the grievance-redressal process.
   • Escalate unresolved complaints through the prescribed regulatory mechanisms, including SCORES 2.0, the designated IAASB and SEBI.
   • Terminate the advisory relationship in accordance with the terms of the client agreement and applicable law.
   • Obtain periodic reports, communications or reviews where these form part of the agreed advisory services.

5. Responsibilities of Investors

   Investors are expected to:

   • Provide complete, accurate and updated information regarding income, assets, liabilities, financial commitments, existing investments, investment objectives, risk appetite and investment horizon.
   • Inform the Investment Adviser promptly about any material change in financial circumstances, investment objectives, risk profile or contact details.
   • Carefully read and understand the client agreement, risk disclosures, fee terms, disclosures and all communications issued by the Investment Adviser.
   • Evaluate the suitability of advice in light of personal circumstances before acting on it.
   • Understand that investment in securities and investment products is subject to market risks.
   • Seek clarification where any recommendation, risk disclosure, fee term or other matter is not understood.
   • Make advisory-fee payments only through banking channels and retain appropriate payment records and receipts.
   • Avoid making cash payments to the Investment Adviser or its representatives.
   • Not share confidential credentials, passwords, OTPs, demat account credentials, bank-account credentials or trading account access with any person unless legally required and independently verified.
   • Maintain proper records of advice received, agreements executed, payments made, communications exchanged and transactions undertaken.
   • Read all scheme documents, offer documents, product literature and risk disclosures relevant to the recommended investment, wherever applicable.
   • Exercise independent judgment before acting on investment advice.

6. Grievance Redressal Mechanism

   1. First-Level Complaint With the Investment Adviser

   Any complaint, query or grievance may first be raised with the Investment Adviser using the following contact details:

   Particulars	Details
   Grievance redressal officer / Compliance Officer	Pradnil Rawale
   E-mail ID	customersupport@jarvisinvest.com
   Telephone number	+91 7400196252
   Postal address	Unit 701, 7th Floor, Dheeraj Kawal, LBS Marg Vikhroli (West) Mumbai 400079
   Working days and hours	10:00 AM to 6:00 PM Monday to Friday.

   The Investment Adviser shall acknowledge and address investor grievances in accordance with the applicable SEBI requirements and internal grievance-redressal policy.

   2. Complaint Through SCORES 2.0

   If an investor is dissatisfied with the response of the Investment Adviser or the grievance remains unresolved, the investor may lodge a complaint on SEBI’s online grievance-redressal platform:

   SCORES 2.0: https://scores.sebi.gov.in

   SCORES 2.0 is SEBI’s web-based centralised grievance-redressal platform intended to facilitate timely handling of investor complaints.

   3. Two-Level Review Mechanism

   For complaints/grievances against the Investment Adviser, the investor may avail the following review mechanism:

   • First review: By the designated body / IAASB.
   • Second review: By SEBI.

   4. Complaint Through IAASB

   The investor may also lodge a complaint with the designated Investment Adviser Administration and Supervisory Body (“IAASB”) at the e-mail address or other contact details notified by the IAASB from time to time.

   Applicable IAASB contact details:

   [Insert relevant IAASB name, e-mail address, web link and any updated complaint-handling details.]

   5. Physical Complaints to SEBI

   For physical complaints, investors may send the complaint 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 (East)
   Mumbai – 400 051

7. Dos and Don’ts for Investors

   Dos

   • Deal only with SEBI-registered Investment Advisers.
   • Verify the IA’s SEBI registration number and registration status before engaging advisory services.
   • Obtain and read the client agreement before availing advisory services.
   • Ensure that the scope of advice, fee structure, payment terms, refund terms and termination provisions are clearly understood.
   • Provide complete and correct information for risk profiling and suitability assessment.
   • Obtain advisory-fee receipts and make payments through banking channels only.
   • Preserve copies of agreements, invoices, fee receipts, advice, e-mails, reports and other communications.
   • Read risk disclosures, offer documents, scheme-information documents and product literature before investing.
   • Seek independent clarification in case of doubt.
   • Use the prescribed grievance-redressal mechanism if any complaint remains unresolved.
   • Review investments periodically in light of personal goals and changes in financial circumstances.

   Don’ts

   • Do not deal with an unregistered person claiming to be an investment adviser.
   • Do not act on any promise or assurance of guaranteed, fixed, assured or risk-free returns.
   • Do not make cash payments for investment-advisory services.
   • Do not share trading, demat or bank-account login credentials, passwords, PINs or OTPs with the Investment Adviser or any other person.
   • Do not issue blank cheques, blank forms, blank delivery instruction slips or blank authorisations.
   • Do not transfer securities, funds or control of demat/trading accounts to the Investment Adviser.
   • Do not invest solely based on social-media tips, unsolicited messages, rumours, advertisements or recommendations received from unauthorised persons.
   • Do not ignore product-specific risks, market risks and liquidity risks.
   • Do not conceal material financial information that may affect suitability assessment.
   • Do not assume that past performance is indicative of future performance.

8. Important Disclosures and Risk Statement

   • Investments in securities markets are subject to market risks. Investors should read all relevant documents carefully before investing.
   • Investment advice is based on information available at the time of providing such advice and on assumptions, analysis and professional judgment. Market conditions and other circumstances may change.
   • The Investment Adviser does not guarantee the performance of any investment or assure any return, income, profit or protection against loss.
   • Past performance of securities, issuers, investment strategies or markets does not indicate or guarantee future performance.
   • The value of investments may rise or fall, and investors may lose part or all of the invested capital.
   • Any decision to invest, hold, sell or otherwise deal in securities shall remain the investor’s own decision and responsibility.
   • Investors should consider their financial position, liquidity requirements, risk tolerance, tax implications and investment horizon before implementing any advice.
   • The Investment Adviser shall disclose actual or potential conflicts of interest in accordance with applicable SEBI requirements.

9. Monthly Disclosure of Complaint Data

   The Investment Adviser shall disclose complaint data received against it and the status of redressal on its website and mobile application, if any, in the prescribed format and within the applicable regulatory timeline. SEBI’s 2 June 2025 circular requires such disclosure to be updated by the 7th day of the succeeding month.

10. Declaration

    This Investor Charter is displayed and made available by Ventugrow Consultants Private Limited, a SEBI-registered Investment Adviser, in accordance with applicable SEBI requirements.

    This Charter is intended to promote transparency, investor awareness and fair dealing. It should be read together with the client agreement, risk disclosures, fee terms and other documents executed or issued in relation to the investment-advisory engagement.