Portfolio Management Services

Investor Charter in respect of Portfolio Management Services

Finnovate Investment Managers Private Limited

SEBI PMS Reg. No.: INP000010104

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A. Vision & Mission B. Business Transacted C. Services & Timelines D. Grievance Redressal E. Investor Responsibilities

A. Vision and Mission Statements for investors

Vision

To implement diligently researched customised investment strategies which 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

Appropriate risk profiling of investors.
To provide Disclosure Document to investors.
Executing the PMS agreement.
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, an investor has 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. 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 decisions 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 act in a fiduciary capacity towards its Client and maintain an arm's length relationship with its other activities.

iii. Client On-boarding

Ensuring compliance with KYC and AML guidelines.
Franking & signing the Power of Attorney to make investment decisions on behalf of the investor.
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.
Mapping the said demat account with the Custodian.

iv. Ongoing activities

To provide periodic statements to investors as provided under the PMS Regulations 2020 and other SEBI notifications and circulars ("PMS Regulations").
Providing each client an audited account statement on an annual basis which 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, an investor's queries, service requests and grievances, if any, on an ongoing basis.

Timelines of the services provided to investors

Sr. No.	Service / Activity	Timeline
1	Opening of PMS account (including demat account) for residents.	7 days from receipt of all requisite documents from the client, subject to review of the documents for accuracy and completeness by the portfolio manager and allied third party service providers as applicable.
2	Opening of PMS account (including demat account) for non-individual clients.	14 days from receipt of all requisite documents, subject to review for accuracy and completeness.
3	Opening of PMS account (including demat, bank and trading account) for non-resident clients.	14 days from receipt of all requisite documents, subject to review for accuracy and completeness.
4	Registration of nominee in PMS account and demat account.	Along with account opening; turnaround time same as account opening.
5	Modification of nominee in PMS account and demat account.	10 days from receipt of requisite nominee modification form, subject to review.
6	Uploading of PMS account in KRA and CKYC database.	10 days from date of account opening (Portfolio Manager may rely on the custodian).
7	SEBI registration number of the portfolio manager.	At the time of client signing the agreement; part of the account opening form and disclosure document.
8	Disclosure about latest networth of portfolio manager and total AUM.	Total AUM disclosed monthly to SEBI; latest networth disclosed in the disclosure document whenever there are material changes.
9–12	Intimation of type of PMS account (discretionary / non-discretionary) and the powers that can be exercised by the portfolio manager.	At the time of client signing the agreement; part of the account opening form.
13	Copy of executed PMS agreement sent to client.	Within 3 days of client request.
14–15	Disclosure of available eligible funds; issuance of funds and securities balance statements held by client.	Quarterly or upon client request.
16	Intimation of name and demat account number of custodian for PMS account.	Within 3 days of PMS and demat account opening.
17–18	Conditions of termination of contract; PMS fees and modes/frequency of deduction.	At the time of client signing the agreement; part of the account opening form.
19	POA copy provided to client.	Within 3 days of client request.
20–24	Transactions under PoA, frequency of audited reports (annual), explanation of risks, tenure of investments, and investor-imposed restrictions.	At the time of client signing the agreement; part of the account opening form.
25–26	Settling of client funds and securities; frequency of intimation of transactions.	Not later than on a quarterly basis or upon client's request.
27	Intimation regarding conflict of interest in any transaction.	Provided in the Disclosure Document, available on the website at all times.
28	Timeline for providing disclosure document to investor.	Latest disclosure document provided prior to account opening and available on the website at all times.
29	Intimation about details of bank accounts where client funds are kept.	Within 3 days of PMS and demat account opening.
30	Redressal of investor grievances.	Within 30 days, subject to all information required to redress the complaint being provided by the complainant.

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

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

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 a complainant can take up his grievance against the PMS provider and subsequently view its status — https://scores.sebi.gov.in.
The details such as the name, address and telephone number of the investor relations officer of the PMS provider who attends to investor queries and complaints are provided in the PMS Disclosure Document.
The grievance redressal and dispute mechanism is mentioned in the Disclosure Document.
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.
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.
If unsatisfied with the response, investors may refer the dispute to the Online Dispute Resolution (ODR) portal — https://smartodr.in/.

Investor Relations Officer: naveen.singh@finnovate.in | +91 98673 25874.

Registered Office: Finnovate Investment Managers Private Limited, 703, The Summit Business Bay, Prakashwadi, Gundavali, Chakala MIDC, Mumbai, Maharashtra 400093, India.

To be confirmed: names of the Principal Officer and Compliance Officer for PMS (as listed in the Disclosure Document).

E. Expectations from the investors (Responsibilities of investors)

Check registration status of the intermediary from the SEBI website before availing services.
Submission of KYC documents and application form in a timely manner with signatures in appropriate places and with requisite supporting documents.
Read carefully the terms and conditions of the agreement before signing the same.
Thorough study of the Disclosure Documents of the PMS to accurately understand the risks entailed by the said investment in PMS.
Accurate and sincere answers to the questions asked in the 'Risk Questionnaire' shall help the PMS provider properly assess the risk profile of the investor.
Thorough study of the quarterly statements sent by the PMS provider intimating the investor about the portfolio's absolute and relative performance, its constituents and its risk profile.
Ensure providing complete details of the negative list of securities as part of freeze instructions at the time of entering into the PMS agreement and every time thereafter for changes, if any, in a timely manner.
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.