Refund and Cancellation Policy

The Adviser provides non-discretionary investment advisory services.

• 2.1 Services Provided

• ◦ Risk profiling and suitability assessment
• ◦ Financial planning and goal-based planning
• ◦ Portfolio construction and recommendations
• ◦ Periodic review and rebalancing recommendations

• 2.2 Services Not Provided

• ◦ Execute transactions
• ◦ Provide assured/guaranteed returns
• ◦ Provide performance-linked or success-based fee structures

• 3.1 Client-Initiated Cancellation

◦ The Client may cancel the advisory services at any time by submitting a written request via:

• ▪ Registered email ID
• ▪ Client dashboard (if available)
• ▪ Physical written communication

◦ Cancellation shall become effective from the date of receipt of such written request by the Adviser.

• 4.1 General Principle

• ◦ Refunds, if any, shall be processed strictly on a pro-rata basis, corresponding to the unutilized portion of the advisory period, in a fair, transparent, and non-discriminatory manner.
• ◦ The Adviser may retain a maximum breakage fee of not greater than one quarter fee.

• 4.2 Full Refund Scenarios

◦ A full refund shall be applicable only in the following cases:

• ▪ Services have not commenced after payment
• ▪ Client onboarding, profiling, and advisory activation have not been initiated

• 4.3 Partial Refund (Pro-Rata Basis)

◦ If services have commenced, refund (if applicable) shall be calculated on a pro-rata basis based on:

• ▪ Duration of service already provided
• ▪ Scope of services already delivered
• ▪ Advisory period remaining

◦ Refund Formula (Illustrative):

• ▪ Refund Amount = Total Fees Paid × (Remaining Advisory Period / Total Advisory Period)

• 4.4 No Refund Scenarios

◦ No refund shall be applicable in the following circumstances:

• ▪ Services have been substantially delivered
• ▪ Personalized advisory recommendations have been generated
• ▪ Portfolio construction and/or implementation support has been provided
• ▪ Periodic reviews/rebalancing recommendations have been initiated
• ▪ Contract period has expired

• 4.5 Upfront Fees and Adjustments

◦ Where fees are collected in advance:

• ▪ Fees shall be adjusted periodically against actual advisory services rendered
• ▪ Any excess fee, after termination, shall be refunded on a pro-rata basis
• ▪ Deficit (if any) shall be payable by the Client

• 5.1 Processing Timeline

◦ All eligible refunds shall be processed within 30 working days from the date of approval of the cancellation request.

◦ Refunds shall be processed through the original mode of payment only.

• 5.2 No Guaranteed Outcomes

◦ Refund eligibility shall notnot be linked to:

• ▪ Portfolio performance
• ▪ Market returns
• ▪ Profit or loss outcomes
• ▪ Market volatility
• ▪ Drawdowns

◦ Investment advisory services are subject to market risks and uncertainties.

• 6.1 Dispute Resolution

◦ Any disputes related to refunds or cancellations shall be resolved in accordance with:

• ▪ Client Agreement
• ▪ SEBI (Investment Advisers) Regulations, 2013
• ▪ Applicable Indian laws

◦ Clients may also use the SEBI SCORES platform for grievance redressal.

• 6.2 Compliance

◦ This Policy is framed in compliance with:

• ▪ SEBI (Investment Advisers) Regulations, 2013
• ▪ SEBI Circulars on fee structure, transparency, and client protection
• ▪ Code of Conduct for Investment Advisers

• 6.3 Policy Updates

◦ The Adviser reserves the right to modify this Policy to remain compliant with regulatory changes. Updated versions shall be published on the website.

Registration granted by SEBI, and certification from NISM, in no way guarantee performance or provide any assurance of returns to investors. Investments in securities markets are subject to market risks. Read all related documents carefully before investing.