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Client Onboarding Policy

No investment is accepted from any person until the steps below are completed. The order is not varied and no step is skipped.

#	Step	What is done
1	First meeting and disclosure	We tell you that we are a distributor, that our commission comes from the Asset Management Company out of the Base Expense Ratio, and that any advice we give is incidental to distribution with no separate fee.
2	Identity and KYC	PAN, proof of identity, proof of address, photograph and bank particulars are collected and verified. KYC is completed through a SEBI-registered KYC Registration Agency or through the Central KYC Registry.
3	In-person verification	In-person verification is carried out and recorded wherever the Aadhaar one-time-password route has not been used.
4	Declarations	FATCA and CRS self-certification is obtained. Beneficial ownership is recorded for non-individual investors. Politically exposed person status is screened at onboarding.
5	Risk categorisation	Each investor is classified as Low, Medium or High risk for anti-money-laundering purposes. The category determines how often the record is reviewed.
6	Risk profiling	The risk profiling questionnaire is completed by the investor in his or her own hand, signed and dated, and placed on file before any scheme is recommended.
7	Bank and nomination	Bank account details in the investor's own name are recorded. A nominee is registered, or the investor's opt-out is recorded in writing.
8	Folio creation and confirmation	The folio is created on the exchange or industry transaction platform. The investor receives the account statement from the Registrar and Transfer Agent directly and is asked to confirm receipt.

Rules that are never relaxed

▪ No transaction is accepted before KYC is complete and in force.

▪ Cash is never accepted from any investor, in any amount, for any purpose.

▪ No cheque or transfer is accepted in the name of the distributor or of any individual. Payment is made only in favour of the Asset Management Company.

▪ The bank account used must belong to the investor. Third-party payments are not accepted except where the scheme documents specifically permit it.

▪ No form is accepted blank, incomplete or unsigned, and no investor is asked to sign a blank form.

▪ The investor's own mobile number and email address are registered in the folio. The distributor's contact details are never registered in place of the investor's.

▪ One-time passwords are never asked for, collected or used by us.

▪ Records are retained for the period prescribed under the applicable statutes and produced on demand.

RISK PROFILING & SUITABILITY POLICY

A scheme is recommended to you only after your capacity and willingness to take risk have been recorded. This policy explains how that is done and how the result is used.

1. How the profile is taken

You complete a written risk profiling questionnaire of ten questions covering your age, income, dependants, existing savings, investment horizon, past experience of market falls, and how you would react to a decline in the value of your investment. You answer the questions yourself. We do not fill the form for you and we do not suggest answers. The completed form is signed, dated and kept on your file.

2. How it is scored

Each question carries four options scored one to four, giving a total of forty marks. The total places you in one of five categories.

Category	Score	What it means
Conservative	14 and below	Protection of capital matters more than growth. Short horizon or low ability to bear a fall.
Moderately Conservative	15 to 20	Some growth sought, with limited tolerance for fluctuation.
Moderate	21 to 26	Balance between growth and stability. Able to bear moderate fluctuation.
Moderately Aggressive	27 to 32	Growth is the main objective. Able to bear significant fluctuation.
Aggressive	33 and above	Maximum growth sought. Able to bear a large fall without changing course.

3. How the profile is used

Every scheme we recommend is checked against your recorded category before the recommendation is made. A suitability matrix maps each category to an acceptable range of equity exposure, to the scheme categories that fit, and to the Riskometer levels that are appropriate. A scheme outside that range is not recommended to you.

4. If you choose something that does not fit

You are free to invest in any scheme you wish. If the scheme you have chosen falls outside your recorded category, we tell you so in writing, explain why it does not fit, and place the transaction only after you have signed a written unsuitability confirmation recording that the choice is your own and that you have been informed. That confirmation is kept on your file.

5. When the profile is refreshed

Your risk profile is reviewed once a year. It is also reviewed sooner if you tell us of a change in your income, your responsibilities, your goals or your investment horizon, or if you ask for a review. A fresh questionnaire is completed on each review and the earlier one is retained.

6. Records

The completed questionnaire, the score, the assigned category, the date of assessment, the recommendation record and any unsuitability confirmation are kept on the investor file for the period prescribed under the applicable statutes and are produced to the Asset Management Company or to the regulator on demand.