FUND SELECTION and REVIEW POLICY

This policy sets out how a scheme reaches the point of being recommended to you, what is checked before an order is placed, and how your holdings are reviewed afterwards.

1. What we do and what we do not do

We are a distributor. Any advice we give is incidental to that distribution and carries no separate fee. We do not manage your portfolio, we do not exercise discretion over your money, and we do not act as an investment adviser or portfolio manager. The decision to invest, to switch or to redeem is always yours.

2. How schemes are shortlisted

We keep a working list of the schemes of the Asset Management Companies with which we are empanelled. A scheme enters the list only after the following have been examined from the scheme documents and from publicly available data:

▪  the scheme category and the SEBI category definition it falls under;

▪  the stated investment objective and where the scheme invests;

▪  the Riskometer level declared by the Asset Management Company;

▪  performance across full market cycles rather than a single recent period, read against the scheme benchmark and the category;

▪  the Base Expense Ratio of the Regular Plan;

▪  the size of the scheme and its liquidity;

▪  portfolio concentration and credit quality, for debt schemes;

▪  the tenure and track record of the fund manager, and any recent change;

▪  exit load and the minimum holding period.

3. Checks before an order is placed

Before any order is sent to the platform we confirm that KYC is complete and in force; that a signed and dated risk profile is on file; that the scheme falls within the category indicated by that profile, or that a signed unsuitability confirmation has been obtained; that the scheme documents and Riskometer have been shown to you; that the commission position has been disclosed; and that the instruction has been received from you in writing or electronically.

4. Review of holdings

Your holdings are reviewed once a year. The review looks at whether the portfolio still matches your recorded risk category, whether any scheme has drifted from its stated mandate, whether performance has fallen persistently behind its benchmark and category over a full cycle, whether the Asset Management Company has changed the scheme's category or objective, and whether a change in your circumstances calls for a change in the portfolio.

5. What a review does not mean

A review is not a promise to time the market, to avoid losses, or to move you out of a scheme before it falls. It is an examination of fit and of mandate. Where the review suggests a change, we explain the reason and the cost, including any exit load and tax effect, and the decision remains yours. We do not recommend a switch or a redemption for the purpose of earning commission, and we do not churn portfolios.

6. Records

The recommendation record, the basis on which the scheme was selected, the date of each review and its outcome are kept on the investor file and are produced to the Asset Management Company or to the regulator on demand.