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We confirm that:
I. the Disclosure Document forwarded to the Board is in accordance with the SEBI (Portfolio Managers) Regulations, 1993 and
the guidelines and directives issued by the Board from time to time;
II. the disclosures made in the document are true, fair and adequate to enable the investors to make a well-informed decision
regarding entrusting the management of the portfolio to us / investment in the Portfolio Management Service;
III. the Disclosure Document has been duly certified by an independent Chartered Accountant, M/s Aneja Associates, Chartered
Accountants, 301, Peninsula Towers, Peninsula Corporate Park, G.K. Marg, Lower Parel (West), Mumbai - 400013 (Name: Mr.
Jugal Aswani having Membership No. 100655) on May 29, 2017. A copy of the certificate issued by the said Chartered
Accountant certifying the disclosures made in the Disclosure Document is enclosed with this letter.
For Avendus Wealth Management Private Limited
Sd/-Mr. George MitraManaging Director & CEOAvendus Wealth Management Private LimitedIL&FS Financial Centre, 5th Floor, B – QuadrantBandra Kurla Complex, Bandra (E)Mumbai 400 051Tel no. +91 22 6648 0050 (Ext: 400)Email address: [email protected]
FORM C
SECURITIES AND EXCHANGE BOARD OF INDIA
(PORTFOLIO MANAGERS) REGULATIONS, 1993
(Regulation 14)
Avendus Wealth Management Private Limited
Date: June 1, 2017
Portfolio�Management�ServicesDisclosure�Document
KEY INFORMATION AND DISCLOSURE DOCUMENT FOR PORTFOLIO MANAGEMENT SERVICES BY AVENDUS WEALTH
MANAGEMENT PRIVATE LIMITED (Regn No.: PM/INP000005257)
• The Disclosure Document (hereinafter referred to as 'the Document') has been filed with the Board along with a certificate
in the prescribed format in terms of Regulation 14 of the SEBI (Portfolio Managers) Regulations 1993.
• The purpose of the Document is to provide essential information about the portfolio services in a manner to assist and
enable the investors in making informed decisions for engaging a Portfolio Manager.
• The necessary information about the Portfolio Manager required by an investor before investing is disclosed in the
Document.
• Investors should carefully read the entire document before making a decision and should retain it for future reference.
• Investors may also like to seek further clarifications after the date of this document from the service provider.
• The Principal Officer, Auditor and Custodian designated by the Portfolio Manager are:
PRINCIPAL OFFICER
Mr. George Mitra
Managing Director & CEO, Avendus Wealth Management Private Limited
IL&FS Financial Centre, 6th Floor, C & D – Quadrant
Bandra Kurla Complex, Bandra (E)
Mumbai 400 051
Tel no. +91 22 6648 0050 (Ext: 400)
Email address: [email protected]
AUDITOR
Deloitte Haskins & Sells
Chartered Accountants,
“Heritage”, 3rd Floor,
Near Gujarat Vidyapith,
Off Ashram Road,
Ahmedabad - 380014
CUSTODIAN
IL&FS Securities Services Limited
IL&FS House, Plot No 14, Raheja Vihar,
Chandivali, Andheri-East,
Mumbai-400072
Table�of�ContentsSr. No. Particulars Page No.
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Disclaimer
Definitions
History, Present Business and background of the Portfolio Manager
Promoters / Directors / Key Personnel of the Portfolio Manager and their background in brief
Key entities in the group
Details of the services being offered: Discretionary/ non-discretionary/ Advisory
Types of Securities to be invested in
Penalties, pending litigation's or proceedings etc. Findings of inspection or investigations forwhich action may have been taken or initiated by any regulatory authority
Risk Factors
Client Representation
Disclosures in respect of transactions with related parties as per the standards specified by the Institute of Chartered Accountants of India
Portfolio Management Performance of the Portfolio Manager
Financial performance of the Portfolio Manager
Nature of costs and expenses for Clients
Taxation implications for clients
Accounting policies / Valuations
Investor services
General
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1. DISCLAIMER� This document has been prepared in accordance with the
Securities and Exchange Board of India (Portfolio Managers) Regulations, 1993 (as amended till date) and has been filed with the Securities and Exchange Board of India (SEBI). This Document has neither been approved or disapproved by SEBI nor has SEBI certified the accuracy or adequacy of the contents of this Document.
2. DEFINITIONS
In this Disclosure Document, unless the context otherwise requires:
a. "Act" means the Securities and Exchange Board of India, Act, 1992 (15 of 1992).
b. “Board” means the Securities and Exchange Board of India.
c. "Cash" means the monies placed by the Client with the Portfolio Manager and any accretions thereto.
d. “Client” or “Investor” means any corporate, partnership firm, individual, HUF, association of person, body of individuals, trust, statutory authority, or any other person who registers with the Portfolio Manager for availing the services of portfolio management.
e. “Corpus” means the value of the funds and the market value of readily realisable investments brought in by the Client and accepted and accounted by the Portfolio Manager.
f. "Custodian" mean any person with whom the custody of the Securities of the Client (whether in physical or dematerialised form) are to be entrusted with, pursuant to the Communication given by the Client from time to time and who has to perform the functions of a custodian of Securities, pursuant to such agreement, understanding or writing as may be executed between the Client and the Custodian or executed between AVENDUS on behalf of the Client with the Custodian.
g. “Depository Account” means any account of the Client or for the Client with an entity registered as a depository participant as per the relevant regulations.
h. "Depository Participant" shall mean any person with whom the Securities of the Client in dematerialized form may be held in an account opened for that purpose pursuant to the Communication given by the Client from time to time and pursuant to such agreement, understanding or writing as may be executed between the Client and the Depository Participant or executed between AVENDUS on behalf of the Client with the Depository Participant.
i. “Non Discretionary Services” shall mean an agreement entered into between a Client and the Portfolio Manager
pursuant to which the Portfolio Manager has agreed to provide Non Discretionary Portfolio Management Services to the Client.
j. “Discretionary Portfolio Manager” shall mean a portfolio manager who exercises or may, under a contract relating to portfolio management, exercises any degree of discretion as to the investments or management of the portfolio of securities or the funds of the client, as the case may be.
k. “Disclosure Document” shall mean the relevant Disclosure Document filed by the Portfolio Manager with SEBI and as may be amended by the Portfolio Manager from time to time pursuant to Regulations.
l. “Financial year” means the year starting from 1st April and ending on 31st March the following year.
m. “Funds managed” means the market value of the Portfolio of the Client as on date.
n. “NAV” or “Net Asset Value” or “Net Asset Value of the Portfolio” shall mean the Market Value of the assets in the Portfolio consisting of the aggregate of (a) the amount of Cash in the Bank Account; and (b) the market value of Client Securities.
o. “Portfolio” means the total holdings of all investments including Securities belonging to the client.
p. “Portfolio Manager” shall have the same meaning as in the SEBI (Portfolio Managers) Regulations, 1993 and for the purpose of this document shall mean Avendus Wealth Management Private Limited (AWMPL), a company incorporated under the Companies Act, 1956 and having its registered office at IL&FS Financial Centre, 6 th Floor, C & D Quadrant, Bandra Kurla Complex, Bandra (East), Mumbai, Pin code: 400 051.
q. “Principal Officer” means an employee of the portfolio manager, who is responsible for the activities of portfolio management and has been designated as Principal Officer by the Portfolio Manager.
r. "Regulations" means the Securities and Exchange Board of India (Portfolio Managers) Regulations, 1993 as amended from time to time.
s. “Securities” shall have the same meaning as in Securities Contracts (Regulation) Act, 1956
Words and expressions used in this disclosure document and not expressly defined shall be interpreted according to their general meaning and usage. The definitions are not exhaustive. They have been included only for the purpose of clarity and shall in addition be interpreted according to their general meaning and usage and shall also carry meanings assigned to them in regulations governing Portfolio Management Services.
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3. HISTORY, PRESENT BUSINESS AND BACKGROUND OF THE PORTFOLIO MANAGER
In early 2010 Avendus Capital Private Limited commenced its Wealth Management Business as a division of Avendus Capital Private Limited. Since its inception the Wealth Management Business has made progress in terms of delivering customer centric advice and solutions to Resident Indians and Non Resident Indians on their Investment Assets.
In view of this progress and to further facilitate the growth of the Wealth Management Business over the next decade the Board of Avendus Capital Private Limited has transferred the Wealth Management Business into a separate subsidiary wholly owned by Avendus Capital Private Limited named Avendus Wealth Management Private Limited with effect from December 1, 2012.
Portfolio Manager leverages insights, relationships and a culture that emphasizes strong orientation to excellence, to offer services to its clients. The Portfolio Manager relies on its extensive experience, in-depth domain understanding and knowledge of the regulatory environment, to offer customized solutions that enable clients to meet their strategic aspirations.
4. PROMOTERS, DIRECTORS & KEY MANAGEMENT PERSONNEL OF THE PORTFOLIO MANAGER AND THEIR BACKGROUND IN BRIEF.
A. Promoters
The Portfolio Manager is subsidiary of Avendus Capital Private Limited ('ACPL). Mr. Ranu Vohra, Mr. Kaushal Aggarwal and Mr. Gaurav Deepak are the promoters of Avendus Capital Private Limited, who collectively hold 20.88% of the equity share capital of ACPL. ACPL and its subsidiaries leverages insights, relationships and a culture that emphasizes strong orientation to excellence, to offer services to its clients. The Group relies on its extensive experience, in-depth domain understanding and knowledge of the regulatory environment, to offer customized solutions that enable clients to meet their strategic aspirations ACPL has headquartered in Mumbai, India and has offices in Bengaluru (erstwhile Bangalore), Kolkata and Gurgaon. The organization has a strong network of relationships in India, and works extensively with clients across the globe. In addition, Avendus Capital Inc. (US) and Avendus Capital (UK) Pvt. Ltd. are the subsidiaries offering M&A and Private Equity syndication services to clients in the respective regions.
B. Particulars of Directors in Avendus Wealth Management Private Limited (Portfolio Manager)
• MR. RANU VOHRA, DIRECTOR
Mr. Ranu Vohra, 45 years, is a Director of the Portfolio Manager. He heads Avendus and is responsible for its overall growth. He has spent the last eighteen years in the Indian financial services industry, concluding several marquee transactions in Investment Banking and Private Equity.
Prior to co-founding Avendus, he worked with a Tampa (USA) based technology and media investment bank, Communications Equity Associates (CEA), and Hinduja Finance, a diversified financial services firm.
He holds an MBA from the Faculty of Management Studies (FMS), Delhi and a BTech in Mechanical Engineering from the Indian Institute of Technology (IIT), Delhi.
� • MR. GEORGE MITRA, MANAGING DIRECTOR & CEO
Mr. George Mitra, MD and CEO, 47 years, is designated as the Principal Officer of the Portfolio Manager.
George has played a pivotal role in growing Avendus' Wealth management franchise and strengthening the NRI business.
Prior to joining Avendus, George worked with Deutsche Bank where he was a key member of the Wealth Management team and the location head for Delhi. He has an overall combined experience of fifteen years in Corporate Finance and Wealth Management.
George has an MBA from the Faculty of Management Studies (FMS) and a BE in Electronics from Jadavpur University.
• MR. NIKHIL KAPADIA, DIRECTOR
Mr. Nikhil Kapadia, 55 years, is a Director of the Portfolio Manager. He holds a Masters in Management Studies from SP Jain Institute of Management & Research, Mumbai and a B.Com from Mumbai University. He is an alumnus of London Business School
Nikhil was Chief Executive Officer of Avendus Wealth Management from January 2010 to April 2014.
Nikhil was the Chief Operating Officer and Head of Business Development for Asia Pacific Onshore Deutsche Bank Singapore (2009-2010). Nikhil was a Member of the Asia Pacific Management Committee (PWM Division) at Deutsche Bank AG. He was responsible for building the onshore Private Wealth Management business of Deutsche Bank in China, Taiwan, Japan, Australia, Indonesia, Thailand and India. He was the Managing Director and Country Head Private Wealth Management, Deutsche Bank India (2004-2009).
Prior to Deutsche Bank AG Nikhil was a Senior Vice President Private Clients at DSP Merrill Lynch. Nikhil was responsible for Building the onshore Private Client
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Business of DSP Merrill Lynch Integrating the business in India with that of Merrill Lynch overseas.
He has also acted as a Head of Investment Management, Cards and Corporate Finance, Oman International Bank Muscat (Oman). Prior to this Nikhil has acted as Vice President at DSP Financial Consultants Ltd Mumbai.
• Rajini Sundar, Director
Ms. Rajini Sundar, has been appointed as a non-executive Director on the Board of the Company with effect from October 5, 2015.
Rajini is a Co-founder and Managing Director of Focus Financial Partners, a leading New York based international partnership of independent Wealth Management firms. Rajini is a management expert with proficiency in organizational structure and effectiveness and is responsible for identifying high-quality Registered Investment Advisors and broker teams to join the partnership.
Prior to founding Focus, Rajini worked at American Express and McKinsey & Company in New York. Rajini holds a MBA from Columbia Business School, New York, a PGDM from the Indian Institute of Management, Ahmedabad and a BA from Delhi University, India. She is a member of the Young President's Organization and serves on the executive committees for both the Financial Services Network and the Women's Network at YPO.
C. Particulars of Key Personnel in Avendus Wealth Management Private Limited (Portfolio Manager)
• MR. GEORGE MITRA, PRINCIPAL OFFICER
Mr. George Mitra, 47 years, is designated as the Principal Officer of the Portfolio Manager.
George has played a pivotal role in growing Avendus' Wealth management franchise and strengthening the NRI business.
Prior to joining Avendus, George worked with Deutsche Bank where he was a key member of the Wealth Management team and the location head for Delhi. He has an overall combined experience of fifteen years in Corporate Finance and Wealth Management.
George has an MBA from the Faculty of Management Studies (FMS) and a BE in Electronics from Jadavpur University.�
• MR. ZARKSIS GOTLA, EXECUTIVE DIRECTOR
Zarksis is part of the senior management team in the firm's Wealth Management division. Mr. Gotla joined Avendus in September 2010. He works closely with the CEO, Mr. George Mitra, in growing the Wealth Management franchise at Avendus.
Prior to joining Avendus, Zarksis worked with Deutsche Bank Private Wealth Management where he spent over 6 years as a key resource and team leader at Mumbai. He was previously with BNP Paribas Wealth Management.
Zarksis is a qualified chartered accountant and has over 16 years' experience spanning Wealth management and Investment Banking.
• MR. ARVIND BANSAL, HEAD OF PRODUCTS AND ADVISORY
Arvind is a part of the senior management team in the firm's Wealth Management division. Mr. Bansal joined Avendus in July 2014. He works closely with the CEO, Mr. George Mitra, in growing the Wealth Management franchise at Avendus.
Prior to joining Avendus, Arvind worked with ING Mutual Fund. He spent over 9 years as a key resource and head of multi manager investments. He previously worked with ICICI Prudential Asset Management Company and KPMG Corporate Finance, amongst others.
Arvind is an Engineer and MBA and has over 17 years' experience.
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5. KEY ENTITIES IN THE GROUP (TOP TEN ON TURNOVER BASIS)
The following are the details of the key entities of Avendus Group are as under:
Avendus Capital PrivateLimited (ACPL)
Avezo Advisors Pvt. Ltd.
Avendus Capital (UK)Private Limited
Avendus PE InvestmentAdvisors Private Limited
Avendus Finance PrivateLimited (formerly knownas Pacific Hire PurchasePrivate Limited)
Sr.No.
Name of Company/ Firm Address Type of Activity HandledNature ofinterest ofDirectors
Nature ofinterest ofPortfolio Manager
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The IL & FS Financial Centre,6th Floor, "C & D" Quadrant,Bandra - Kurla Complex,Bandra (East),Mumbai - 400 051Tel :-+91 22 66480050
Discovery of India Building,11th Floor, Nehru Centre,Dr. Annie Besant Road,Worli, Mumbai-400 018,India Tel :-+91 22 61108484
33, St James's Square, London SW1Y 4JS
The IL & FS Financial Centre,6th Floor, "C & D" Quadrant,Bandra - Kurla Complex,Bandra (East),Mumbai - 400 051Tel:- +91 22 66480050
The IL & FS Financial Centre,6th Floor, "C & D" Quadrant,Bandra - Kurla Complex,Bandra (E), Mumbai - 400 051
To provide InvestmentBanking, Merchant Banking,M&A Advisory,Private Equity syndicationand Structured financeadvisory
Avezo Advisors is engagedin the business ofinvestment management.Avezo Advisors act asInvestment manager toSEBI registered AlternativeInvestment Funds. AvezoAdvisor also providesportfolio managementservices.
To carry out InvestmentBanking activities in UK
Avendus PE is acting assponsor to SEBI registeredAlternative InvestmentFund as a part of Avendusgroup.
RBI registered NBFC(non-deposit accepting).Its activities are loans,advances and investment.
DirectorRanu Vohrais director ofthe Company.
HoldingCompany
AssociateCompanyof AvendusCapita PrivateLimited
Whollyownedsubsidiaryof ACPL
Whollyowned Subsidiaryof AvendusCapitalPrivateLimited
Whollyownedsubsidiaryof ACPL
DirectorRanu Vohrais the commondirector withthe Company
DirectorRanu Vohra is the commondirector with the Company
Diligent InvestmentAdvisors Limited
6 33,Edith Cavell Street,Port Louis, Mauritius
FSC registered(CIS Manger License andCategory 1 Global Business License)
None, it is aspecialpurposevehicle.
Whollyownedsubsidiaryof ACPL
Avendus Capital PublicMarkets AlternateStrategies LLP
7 The IL & FS Financial Centre,6th Floor, "C & D" Quadrant,Bandra - Kurla Complex,Bandra (E), Mumbai - 400 051
Manager and sponsor of Avendus Alternate India Fund which is a Category III– Alternative InvestmentFund registered with SEBI.
Ranu Vohrais DesignatedPartner of LLP
ACPL is apromotingentity
DirectorRanu Vohra is the commondirector with the Company
None
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5. KEY ENTITIES IN THE GROUP
The following are the details of the key entities of Avendus Group, the ultimate parent and its subsidiaries.
Avendus Capital INC.
Avendus Capital (UK)Private Limited
Sr.No.
Name of Company/ Firm Address Type of Activity HandledNature ofinterest ofDirectors
Nature ofinterest ofapplicantcompany
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445 Park Avenue, 19th Floor,New York, NY 10022call+1 646 707 0789
33, St James's Square,London SW1Y 4JScall+44 203 159 4353
Avendus Capital, Inc isregistered with FinancialIndustry RegulatoryAuthority in the US andprovides InvestmentBanking services. In addition Avendus Capital,Inc. is also registered withthe State Securities Boardsof New York, New Jersey,California and Texas to actas a Registered InvestmentAdvisor.
Avendus Capital (UK)Private Limited is registeredwith Financial ConductAuthority (FCA) and carryout Investment Bankingactivities.
Subsidiaryof AvendusCapitalPrivateLimited
WhollyownedSubsidiaryof AvendusCapitalPrivateLimited
No commonDirector
No commonDirector
Red Point InvestmentsPte. Ltd.
10 10 Changi Business ParkCentral 2, #05-01Hansapoint@CBP,Singapore 486030
The Company is the holdingCompany of ACPL
The PortfolioManager is asubsidiary ofACPL andACPL is asubsidiary ofRed PointInvestmentsPte. Ltd.
NIL
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6. DETAILS OF THE SERVICES BEING OFFERED: DISCRETIONARY/ NON-DISCRETIONARY/ ADVISORY
The Portfolio Manager offers Portfolio Management services under Non Discretionary, Discretionary and Advisory categories to its prospective clients.
• Non Discretionary Services
Under these services, the choice as well as the timings of the investment decisions rest solely with the Client. The Portfolio Manager shall manage the funds in accordance with the directions of the client. The role of the Portfolio Manager is merely to provide non binding advice to the client and the final decision shall rest solely with the client on the management of his/hers/its portfolio.
• Discretionary Services
The Portfolio Manager shall have the sole and absolute discretion to invest on behalf of the client in any type of security as per executed Agreement and make such changes in the investments and invest some or all of the Funds in such manner and in such markets as it deems fit. The Portfolio Manager's decision (taken in good faith) in deployment of the Clients' account is absolute and final and cannot be called in question or be open to review at any time during the currency of the Agreement or any time thereafter except on the ground of malafide, fraud, conflict of interest or gross negligence. This right of the Portfolio Manager shall be exercised strictly in accordance with the relevant acts, rules and regulations, guidelines and notifications in force from time to time.
• India Discovery Portfolio
Investment Objective: Bottom up approach for selection of small and mid-cap stocks having
• Superior ROCE over a period of time
• Good Management & Corporate Governance Standards
• Increasing addressable business size
• Turnaround stories
• Under valued
Sector Focus: Sector Agnostic
Investment Horizon: 36 Months (minimum)
Portfolio Positioning: Should form a part of high risk asset allocation
Avendus India Alpha Fund (Formerly known as Diversified Portfolio)
Investment Objective: To provide capital appreciation by predominantly investing in high quality companies run by strong management that are likely to post robust growth and demonstrate superior operational efficiency
Sector Focus: Diversified sector exposure to benefit from the India growth story
Investment Horizon : 12-18 Months
Portfolio Positioning : “Core” portfolio of an investor's equity allocation
• AWMPL-Select Sector Portfolio
Investment Objective: The objective of the Portfolio is to invest in high quality businesses which are attractively valued with strong and improving fundamentals in industries with favourable industry dynamics and outperform the benchmark.
Sector Focus: Concentrated exposures in a few select sectors
Investment Horizon : 36 Months (minimum)
Portfolio Positioning : Should form a part of high risk asset allocation
• AWMPL-Special Situations Value
Investment Objective: The objective of the Portfolio is long term (more than 3 years) capital appreciation by investing in two kinds of opportunities:
1) Special Situations and
2) Value Opportunities
Sector Focus: Sector Agnostic
Investment Horizon: 36 Months (minimum)
Portfolio Positioning : Should form a part of high risk asset allocation
• Resurgent Portfolio –
Investment Objective: To provide capital appreciation by predominantly investing in high quality cyclical that are likely to do well with the new government focusing on growth.
Sector Focus : Concentrated sector exposure to benefit from the India Growth Story
Investment Horizon : 12-18 Months
Portfolio Positioning : Should from a part of high risk asset allocation
• Mid Cap Portfolio –
Investment Objective: The diversified equity funds seek to provide long term capital appreciation by investing in mid and small cap companies.
Sector Focus : Stock picking, macro skills, risk management support and understanding of valuation form the hallmark of the portfolio
Portfolio Positioning : Sector likely to reap rich harvest from cyclical upturn well represented
• Advisory Services
The Portfolio Manager will provide advisory services, in the nature of investment advisory which shall include advising on investment / divestment of individual securities on the Client's
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Portfolio for an agreed fee to all eligible categories of investors who can invest in Indian market including NRIs, FIIs, etc. The role of the Portfolio Manager is merely to provide non binding advice to the client and the final decision shall rest solely with the client on the management of his/hers/its portfolio.
7. TYPES OF SECURITIES TO BE INVESTED IN
The types of securities in which the Portfolio Manager will generally invest or advise are:
• Shares, scrips, stocks, bonds, debentures, debenture stock or other marketable securities of a like nature in or of any incorporated company or other body corporate;
• Derivatives;
• Units or any other instrument issued by any scheme to the investors in such schemes;
• Security receipt as defined in clause (zg) of section 2 of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002;
• Units or any other such instrument issued to the investors under any mutual fund scheme;
• Government securities;
• Such other instruments as may be declared by the Central Government to be securities; and
• Rights or interest in securities;
The Portfolio Manager will not invest in associate or group companies of the Portfolio Manager
8. PENALTIES, PENDING LITIGATIONS OR PROCEEDINGS ETC. FINDINGS OF INSPECTION OR INVESTIGATIONS FOR WHICH ACTION MAY HAVE BEEN TAKEN OR INITIATED BY ANY REGULATORY AUTHORITY
(I) All cases of penalties imposed by the Board or the directions issued by the Board under the Act or Rules or Regulations made there under.
Nil
(ii) The nature of penalty or direction
Nil
(iii) Penalties imposed for any economic offence and/ or for violation of any securities laws.
Nil
(iv) Any pending material litigation/legal proceedings against the portfolio manager/key personnel with separate disclosure regarding pending criminal cases, if any.
Nil
(v) Any deficiency in the systems and operations of the portfolio manager observed by the Board or any regulatory agency.
Nil
(vi) Any enquiry/ adjudication proceedings initiated by the Board against the portfolio manager or its directors, principal officer or employee or any person directly or indirectly connected with the portfolio manager or its directors, principal officer or employee, under the Act or Rules or Regulations made thereunder.
Nil
9. RISK FACTORS� (a) Securities investments are subject to market and other
risks and the Portfolio Manager provides no guarantee or assurance that the objectives of investments set out in the Disclosure Document and/or the Portfolio Management Services Agreement will be achieved.
(b) Past performances of the Portfolio Manager or of the key personnel of the Portfolio Manager do not guarantee its/their future performance.
(c) The Portfolio Manager has limited experience or track record.
(d) Investments made by the Portfolio Manager are subject to risks arising from the investment objective, investment strategy and asset allocation.
(e) Investments are subject to market risk arising out of non diversification, if any.
(f) Acts of State, or sovereign action, acts of nature, acts of war, civil disturbance are extraneous factors which can impact the Portfolio.
(g) Prospective clients should review / study the Disclosure Document carefully and in its entirety and shall not construe the contents hereof or regard the summaries contained herein as advice relating to legal, taxation, or financial / investment matters and are advised to consult their own professional advisor(s) as to the legal, tax, financial or any other requirements or restrictions relating to the subscription, gifting, acquisition, holding, disposal (sale or conversion into money) of Portfolio and to the treatment of income (if any), capitalisation, capital gains, any distribution, and other tax consequences relevant to their Portfolio, acquisition, holding, capitalisation, disposal (sale, transfer or conversion into money) of Portfolio within their jurisdiction of nationality, residence, incorporation, domicile etc. or under the laws of any jurisdiction to which they or any managed funds to be used to purchase/gift portfolio of securities are subject, and also to determine possible legal, tax, financial or other consequences of subscribing / gifting, purchasing or holding portfolio of securities before making an investment.
(h) Changes in Applicable Law may impact the performance of the Portfolio.
(i) Credit Risk: Debt securities are subject to the risk of the issuer's inability to meet the principal and interest
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10. CLIENT REPRESENTATION
The Portfolio Manager has commenced operations w.e.f May 18, 2010 and offers Portfolio Management Services covering Discretionary, Non Discretionary and Advisory Services.
Details of Clients are as below:
payments on the obligations and may also be subject to the price volatility due to such factors as interest sensitivity, market perception, or the credit worthiness of the issuer and general market risk.
(j) Interest Rate Risk: This risk is associated with movements in interest rates, which depend on various factors such as government borrowing, inflation, economic performance etc. The value of investments will appreciate/depreciate if the interest rates fall/rise. Fixed income investments are subject to the risk of interest rate fluctuations, which may accordingly increase or decrease the rate of return thereon. When interest rates decline, the value of a portfolio of fixed income securities can be expected to rise. Conversely, when interest rates rise, the value of a portfolio of fixed income securities can be expected to decline.
(k) Mutual Fund Risk: This risk arises from investing in units of Mutual funds. Risk factors inherent to equities and debt
securities are also applicable to investments in mutual fund units. Further, scheme specific risk factors of each such underlying scheme, including performance of their underlying stocks, derivatives instruments, stock lending, off-shore investments etc., will be applicable in the case of investments in mutual fund units. In addition, events like change in fund manager of the scheme, take over, mergers and other changes in status and constitution of mutual funds, foreclosure of schemes or plans, change in government policies could affect performance of the investment in mutual fund units.
(l) Reinvestment Risk: This risk arises from the uncertainty in the rate at which cash flows from an investment may be reinvested. This is because the returns from reinvestment would depend upon prevailing market rates at the time that the proceeds from an existing investment are received by the Portfolio Manager.
Category ofClients
Discretionary / Non Discretionary / Advisory
No. of clients
Funds Managed (Rs. Cr.)
30-Apr-17 31-Mar-16Funds
Managed (Rs. Cr.)
No. of clients
No. of clients
Funds Managed (Rs. Cr.)
31-Mar-17 31-Mar-15Funds
Managed (Rs. Cr.)
No. of clients
Individual- Non- 152 1,526.28 152 1,522.58 107 602.55 70 363.08Resident Discretionary Discretionary 75 155.85 76 132.91 33 66.93 26 92.86 Advisory 12 336.90 12 349.36 16 382.00 16 358.44
Non Resident Discretionary 25 155.21 26 139.25 29 124.72 30 224.50Indian
Corporate Non- 34 1,111.40 35 1,087.44 28 908.52 16 533.81 Discretionary Discretionary 20 81.32 15 17.45 6 2.25 6 3.97
Corporate Advisory 6 1,194.42 7 1,215.81 8 501.15 7 88.19
Total 324 4,561.38 323 4,464.81 227 2,588.12 171 1,664.85
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(c) Details of related party transaction during the year end balances at the end of the year
Nature of Transaction
AvendusCapital Private Limited
TotalKMP
Note: There are no amounts written off or written back during the year for debts due from or to related parties. Previous year figures are given in brackets
Nature of RelationshipSr. No. Name of the related party
(b) Names of related parties where there were transactions during the year:
(Amount in Rupees)
Avendus PE Investment Advisors
Private Limited
Avezo AdvisorsPrivate Limited
AvendusCapital Inc.
11. DISCLOSURES IN RESPECT OF TRANSACTIONS WITH RELATED PARTIES AS PER THE STANDARDS SPECIFIED BY THE
INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA.
Transactions with Related Parties (based on audited accounts for the year ended March 31, 2016)
RELATED PARTY DISCLOSURES
(a) Names of Related Parties where control exists :
Nature of RelationshipSr. No. Name of the related party
Avendus Capital Private Limited Holding Company1
1 Avendus Capital Private Limited Holding Company
2 Avendus PE Investment Advisors Private Limited Fellow Subsidiary
3 Avendus Capital Inc. - USA Fellow Subsidiary
4 Avezo Advisors Private Limited Fellow Subsidiary up to January 28, 2016
5 George Mitra Key Management Personnel (KMP)
6 Kartik Kini, Nikhil Kapadia, and Zarksis Gotla Key Management Personnel (KMP) up to March 31, 2015
Cost Sharing Expenses 51,600,000 - - - - 51,600,000 (45,200,000) (-) (-) (-) (-) (45,200,000)
Issue of Equity Shares – 49,999,910 - - - - 49,999,910including premium (52,548,000) (-) (-) (-) (148,310) (52,696,310)
Issue of Preference Shares – - - - - 7,372,827 7,372,827including premium (-) (-) (-) (-) (-) (-)
Issue of Compulsorily 59,490,900 - - - - 59,490,900Convertible Debentures (-) (-) (-) (-) (-) (-)
Remuneration Paid - - - - 21,500,000 21,500,000 (-) (-) (-) (-) (51,094,509) (51,094,509)
Advisory Fee – Income - - - 4,775,593 - 4,775,593 (-) (11,052,167) (-) (3,322,631) (-) (14,374,798)
Consultancy Fee/ Management - - 4,765,688 - - 4,765,688Fee Expenses (-) (-) (17,881,265) (-) (5,500,000) (23,381,265)
Closing Balances - Debit - - - - - - (-) (964,245) (-) (818,880) (-) (1,783,125)
Closing Balances – Credit 28,815,099 - - - 4,000,000 32,815,099 (14,545,622) (-) (533,649) (-) (10,080,000) (25,159,271)
10
12. PORTFOLIO MANAGEMENT PERFORMANCE OF THE PORTFOLIO MANAGER
The performance of the Portfolio Manager under Discretionary Portfolio Manager Service based on XIRR method as on 31-03-2017 is as follows:
Particulars2015-2016
Amount (in Rs.)
2014-2015 2012-2013
FY 17-18(April 01, 2017 to May 28, 2017) FY 15-16
13. FINANCIAL PERFORMANCE OF THE PORTFOLIO MANAGER
FY 16-17
The net worth of the portfolio manager is Rs. 11.49 Crs. as on 31-03-2016 based on audited accounts of Avendus Wealth Management Private Limited, thereby complying with the capital adequacy requirements of SEBI.
14. NATURE OF COSTS AND EXPENSES FOR CLIENTS
� The following are indicative types of costs and expenses for clients availing the Portfolio Management services.
Nature of RelationshipSr. No. Name of the related party
The detailed description of the fees, expenses and compliance with SEBI Circular IMD/DF/13/2010 dated October 5, 2010 relating to Performance fees including high water mark principle is given in Schedule A: Fees and Charges of the Client Member Agreement.
Clients can avail distribution or execution services from any entity of their choice. Clients are hereby informed that Emkay Global Financial Services Limited (Emkay) is a SEBI registered stock broker, through which clients trade are executed apart from other stock brokers. Portfolio Manager receives commission from Emkay for the trades executed on behalf of client through Emkay. Further, associates and other departments of the Portfolio Manager may receive fees from the third parties in connection with investment of fund of clients in the products of third parties.
Total Income 169,571,401 200,814,402 117,880,393
Profit / (Loss) after Tax (75,329,039) (36,438,139) (85,564,311)
Paid up Capital 67,237,735 60,534,440 55,485,450
Reserves & Surplus (Including ESOP Outstanding) 47,344,021 5,623,177 (5,586,008)
Networth 114,903,150 66,373,756 49,998,901
A Management Advisory Fee 6%
Upfront Fee 6%
Annual Recurring Fee 3%
Performance Linked Fee 25% of annualized performance above a pre-determined hurdle rate can be
charged by the Portfolio Manager as performance linked fee
Exit Charge 6%
B Fund Accounting & Audit At actual
C Custodian Fee At actual
D Registrar & Transfer Agent Fee At actual
E Brokerage & Transaction Cost 1.5%
F Securities lending charges At actual
G Certification and professional charges At actual
H Incidental Expenses At actual
FY 14-15
Portfolio Performance of Portfolio manager (%) 21.30% 21.10% -3.38% 15.40%
NSE Nifty (Benchmark Index) Performance (%) 34.00% 18.90% -10.43% 25.50%
CRISIL Bond Index 8.50% 10.70% 8.10% 14.70%
FY 15-16
11
15. TAXATION IMPLICATIONS FOR CLIENTS
The information furnished below outlines briefly the tax
implications to the investors and is based on relevant
provisions of the Income-tax Act, 1961 as amended by
Finance Act 2015. (“the Income Tax Act”), Wealth-tax Act,
1957 and Gift Tax Act, 1958, (collectively called 'the relevant
provisions') as at 31st May, 2015. The information below is
based on the relevant provisions as on 31st May, 2015 any
subsequent changes in the said provisions could affect the
tax benefits.
THE FOLLOWING INFORMATION IS PROVIDED FOR
GENERAL INFORMATION PURPOSES ONLY AND
APPLIES TO THE PORTFOLIO. IN VIEW OF THE
INDIVIDUAL NATURE OF TAX BENEFITS, EACH
INVESTOR IS ADVISED TO CONSULT HIS OR HER OWN
TAX CONSULTANT WITH RESPECT TO THE SPECIFIC
TAX IMPLICATIONS ARISING OUT OF HIS OR HER
PARTICIPATION IN THE PORTFOLIO. THE SPECIFIC TAX
IMPLICATIONS FOR EACH TYPE OF INVESTMENT
WOULD DEPEND ON THE TYPE OF THE INVESTMENT
AND ITS INDIVIDUAL CHARACTERISTICS AND HAVE
NOT BEEN SPECIFICALLY DEALT WITH HEREUNDER.
THIS SECTION DOES NOT INCLUDE THE TAX
PROVISIONS OF NEW PENSION SYSTEM TRUST
ESTABLISHED ON THE 27TH DAY OF FEBRUARY 2008
UNDER THE PROVISONS OF INDIAN TRUSTS ACT, 1882
(2 OF 1988).
a) Dividend
Income by way of dividends distributed by domestic
companies and income received in respect of units of a
Mutual Fund registered with SEBI, held in the Portfolio, is
exempt from tax in the hands of the investors.
b) Capital Gains
It is assumed that the activity of purchase and sale of shares /
securities by the investors would be regarded as investment
activity and not business activity. What is stated hereunder in
this and subsequent paragraphs [subject to what is stated in
section (h) below] is on this premise.
I. Long term Capital Gains
Shares in a company, units of a Mutual Fund registered with
SEBI and other listed securities held as capital assets are
treated as long term capital assets if they are held for a period
of more than twelve months preceding the date of transfer.
A. Under section 112 of the Income Tax Act, capital gains
arising from transfer of a long term capital asset being
listed securities or units or zero coupon bond (as defined
therein) (subject to what is stated below) in case of both
resident and non-resident investors [subject to what is
stated in (g) below] will be taxable at the rate of 10 percent
without indexation or 20 percent with indexation in case
of Resident, whichever is lower (plus applicable
surcharge and educational cess and secondary and
higher education cess). No indexation benefit is however,
available in computing long-term capital gain arising from
the transfer of a long-term capital asset being bond or
debenture other than capital indexed bonds issued by the
Government.
From the full value of consideration, the following
amounts are deductible to arrive at the amount of long-
term capital gains:
i. Cost of acquisition as adjusted by the cost inflation
index notified by the Central Government in the Official
Gazette; and
ii. Expenditure incurred wholly and exclusively in
connection with such transfer.
Listed bonds and debentures, other than capital indexed
bond issued by Central Government, will be taxable at
the rate of 10 percent without indexation.
Where in case of an individual or an HUF, being a
resident, the total income as reduced by such long term
capital gains is below the maximum amount which is not
chargeable to income tax, then such long term capital
gains shall be reduced to the extent of such shortfall and
only the balance of the long term capital gains will be
subject to the flat rate of taxation.
B. Under section 10(38) of the Income Tax Act, capital gains
arising from transfer of a long term capital asset being
equity shares or units of an equity oriented fund (as
defined therein) and the transaction of sale of such equity
share or units is entered into on or after 1st October,
2004, and where such transaction is chargeable to
securities transaction tax, is exempt from income tax.
II Short term capital gains
A. Securities, including units of a mutual fund, held as a
capital asset for not more than twelve months preceding
the date of their transfer are short-term capital assets.
Capital gains arising from the transfer of short-term
capital assets (other then equity shares or units of an
equity oriented fund referred to in section 111A read with
section 10(38) of the Income Tax Act) will be subject to
tax at the normal rates of tax applicable to such investor
(as increased by applicable surcharge and educational
cess and secondary and higher education cess).
B. Capital gains arising from transfer of a short term capital
asset being equity shares or units of an equity oriented
fund referred to in section 111A read with section 10(38)
12
of the Income Tax Act, and where such transaction is
chargeable to securities transaction tax, is taxable at the
rate of 15% (plus applicable surcharge and educational
cess and secondary and higher education cess).
Where in case of an individual or an HUF, being a
resident, the total income as reduced by such short term
capital gains is below the maximum amount which is not
chargeable to income tax, then such short term capital
gains shall be reduced to the extent of such shortfall and
only the balance of the short term capital gains will be
subject to the flat rate of taxation.
III. Avoidance of Tax by Certain Transactions in
Securities
As per section 94(7) of the Income Tax Act, losses arising
from the sale / transfer of any securities / units (including
redemption) purchased up to 3 months prior to the record
date and sold within 3 months (in case of units 9 months)
after such date, will be disallowed to the extent of
dividend / income distribution (excluding redemptions)
on such securities / units claimed as tax exempt by the
shareholder / unit holder.
Further, section 94(8) of the Income Tax Act provides that
any person who buys or acquires any units within a
period of 3 months prior to the record date and such
person is allotted additional units without consideration
(bonus units) based on the original holding, any
subsequent loss on sale of original units within a period of
9 months from the record date, will be ignored for
computing the income chargeable to tax. The loss so
ignored will be deemed to be the cost of purchase or
acquisition of Bonus units (held at such time) when these
Bonus units are subsequently sold.
c) Taxation of Income from investment in Listed
Debentures:
d) Surcharge
A surcharge of 7.0 percent and 12.0 percent is levied on tax
payable by Domestic corporate assesses only if total income
exceeds Rs.10,000,000/- and 1,00,000,000 respectively. In
case of Companies other than Domestic Company surcharge
is 2.0 percent and 5.0 percent if total income exceeds Rs.
10,000,000/- and 1,00,000,000 respectively. Further,
surcharge of 15 percent is levied on the tax payable by
individuals / Hindu Undivided Families/ Body of Individuals
and Association of Persons and firm only if total income
exceeds 10,000,000. Accordingly, the rates of tax mentioned
above, will be increased by applicable surcharge.
e) Education Cess
� An education cess of 2 percent and secondary and higher
education cess 1 percent is levied on tax payable including
surcharge, if any, by all the assesses. However, no education
cess and secondary and higher education cess is levied on
TDS amount.
f) Securities Transaction Tax (STT)
STT is chargeable in respect of taxable securities transaction
as per the table below:
g) Special Provisions for Non-Resident Investors
i. Exchange Rate Fluctuation
As per the first proviso to section 48 of the Income Tax Act
when a non-resident sells shares or debentures of an
Indian company, the capital gain thereon shall be
computed by converting the cost of acquisition,
expenditure incurred wholly and exclusively in
connection with such transfer and the sale consideration
to the same currency that was initially utilized to purchase
the shares or debentures, calculating the gain thereon
and re-converting the gain into Indian Rupees for the
purpose of taxation. The benefit of adjusting the cost of
Income Rate of Tax
Interest
Short Term Capital Gain(Held for 12 months or less)
Long Term Capital Gain(Held for More than 12 Months)
Normal rates of taxapplicable to such investor
10% without indexation
Normal rates of taxapplicable to such investor
Taxable Securities Transaction Rate
Nil
Purchaser to pay 0.125%Seller to pay0.01 %
Seller to pay 0.001%
iv.
Purchase of units of an Equity orientedFunds entered through a recognisedstock exchange & settled by actualdelivery or transfer of unit
(b) Sale of an option in Securities, where an option is exercised (c) Sale of futures in Securities
Sale of units of an equity orientedFund to the Mutual Fund
0.1 % each on purchase & sale
i. Purchase & sale of Equity Share in acompany entered through a recognisedstock exchange & settled by actualdelivery or transfer of such share or unit
Seller to pay0.05%
iii. (a) Sale of an option in Securities
ii. Sale of equity share in a company or aunit of an equity oriented fund enteredthrough a recognised stock exchange &settled otherwise than by actual deliveryor transfer of such share or unit
Seller topay 0.025 %
13
acquisition with the cost inflation index is not available in
this case.
ii. Benefit of Double Taxation Avoidance
Agreement
As per the provisions of Section 90(2) of the Income
Tax Act, the provisions of the Double Taxation
Avoidance Agreement (“DTAA”) or the Income Tax
Act, whichever are more beneficial to the assesse
shall apply. Accordingly, if the Investor is a resident of
a treaty country, the provisions of the DTAA or of the
Income Tax Act, whichever are more beneficial to the
Investor, shall apply.
iii. Chapter XIIA benefits
The provisions of Chapter XIIA of the Income Tax Act
provide for beneficial tax treatment for investment
income of Non-resident Indians, from investment in
specified assets purchased in convertible foreign
exchange. Specified assets inter alia include:
a. Shares in an Indian Company
b. Debentures issued by an Indian Company (other
than a private company)
c. Deposits with an Indian company which is not a
private company.
d. Any security of central Government.
e. Any other notified Assets (No asset has been
notified as yet)
Investment Income (other than dividends declared by
an Indian company) [as defined] is taxable at 20% (as
increased by the applicable surcharge and education
cess and Secondary and Higher Education Cess) and
specified long-term capital gains are chargeable to
tax at 10% (as increased by the applicable surcharge
and education cess and secondary and higher
education cess ).
The Investor has the option to be governed either by
the provisions of Chapter XIIA or the normal
provisions of the Income Tax Act.
iv. Tax deducted at source
Presently, tax is withheld at source for non- residents. If any
tax is required to be withheld on account of any future
legislation, the Portfolio Manager shall be obliged to act in
accordance with the regulatory requirements in this regard.
Any person entitled to receive any sum or income or amount,
on which tax is deductible under Chapter XVIIB (hereafter
referred to as deductee) on or after 1/04/2010, shall furnish
his Permanent Account Number to the person responsible for
deducting such tax (hereafter referred to as deductor), failing
which tax shall be deducted at the higher of the following
rates, namely:
(i) at the rate specified in the relevant provision of this
Income Tax Act; or
(ii) at the rate or rates in force; or
(iii) at the rate of twenty per cent.
Education cess @2% and higher education cess @1%
is applicable in case of TDS for NRI clients.
h) Special provisions relating to derivatives
The Finance Act, 2005 has inserted clause (d) in the proviso
to section 43(5) of the Income Tax Act to provide that
specified transactions in derivatives would not be deemed to
be “speculative transactions”. Accordingly, the amount
received/ paid on settlement of the contract for such
derivative transactions would not be regarded as speculation
gain/ loss. Such receipt/ payment would normally be
regarded as business income/ loss. Deviation, if any, would
depend on the specific facts and circumstances attributable
to each investor.
16. ACCOUNTING POLICY / VALUATIONS
The Client Securities shall be valued based on the following
principles:
• The Portfolio Manager shall keep and maintain proper
books of accounts, records and documents, for each
Client so as to explain transactions for each Client and to
disclose at any point of time the financial positions of
each of the Client and in particular to give a true and fair
view of the state of affairs of the Portfolio of each Client;
• Where the Security (equity and equity related instrument)
is traded on NSE the day's closing price on NSE will be
considered for valuing Securities. If it is not traded on
NSE, then the day's closing price on BSE will be
considered. If the Security is not traded on either
exchange on that day, then the last traded price will be
considered. However, if the Security is not traded for 30
days preceding the valuation date, then the Security shall
be treated as non-traded security and valued
accordingly.
• The previous day's scheme NAVs or latest NAVs
declared by Mutual Funds [as per The Association of
Mutual Funds in India (AMFI) website] will be used to
value Mutual Fund investments.
• For the purpose of financial statements, the Portfolio
Manager shall mark all the investments on mark to
market. Investments will be marked at cost where market
price is not available (e.g. unlisted Securities).
• Dividend income shall be tracked from the date of
declaration and recognized on the date of the security
being quoted on an ex-dividend basis. For unlisted
14
investments, dividend income would be recognized on
the date of declaration.
• Bonus units shall be tracked from the date of declaration
and recognized on the date of the Security being quoted
on an ex-bonus basis. For unlisted investments, bonus
units would be recognized on the date of declaration.
• Rights units shall be recognized on the date of the
security being quoted on an ex-rights basis.
• In respect of all interest bearing investments, income
shall be, unless otherwise provided for, accrued on a
daily basis as it is earned. Therefore, when such
investments are purchased, interest paid for the period
from the last interest due date up to the date of purchase
shall be treated as interest receivable and not added to
the cost of purchase.
• First In First Out (FIFO) method shall be followed to
determine the holding cost of investments and profit/ loss
on sale of investments.
• Purchase and sale transactions shall be recognized on
the trade date and not as of the settlement date, so that all
the investments made during a period are recorded and
reflected in the same period. Where investment trades
are made outside the stock exchange (example units of
mutual fund, private equity, etc.), the purchase
transaction would be recorded as of the date on which the
Client obtains an enforceable obligation to pay the
purchase consideration and the sale transaction would
be recorded as of the date on which the Client obtains an
enforceable right to collect the sale consideration.
• Where any income receivable on investments has
accrued and is due but not received for a period of greater
than 6 months adequate provisions shall be made.
• The cost of investments acquired and/or purchased shall
include all such costs incurred for effecting such
acquisition/purchase. In respect of privately placed
Securities, any front end discount offered shall be
reduced from the cost of investment
The accounting policies and standards as stated above may
be modified from time to time by the Portfolio Manager,
subject to such modifications being in conformity with the
applicable regulations.
17. INVESTOR SERVICES
A. Contact information
Name, address and telephone number of the investor
relations officers who shall attend to the investor queries
and complaints.
Name : Ms. Priya Sonavane
Address : Avendus Wealth Management
Private Limited
IL&FS Financial Centre, 6th Floor, C & D –
Quadrant Bandra Kurla Complex, Bandra
(East), Mumbai 400 051
Tel: +91 22 6648 0050/ 66481437
Email: [email protected]
The official mentioned above will ensure prompt investor
services. The Portfolio Manager will ensure that these
officials are vested with the necessary authority,
independence and the wherewithal to handle investor
complaints.
B. Grievance Redressal And Dispute Settlement
Mechanism
The Portfolio Manager will endeavor to address all
complaints regarding service deficiencies or causes for
grievance, for whatever reason, in a reasonable manner
and time. If the investor remains dissatisfied with the
remedies offered or the stand taken by the Portfolio
Manager, the investor and the Portfolio Manager shall
abide by the following mechanisms.
All disputes, differences, claims and questions
whatsoever arising between the Client and the Portfolio
Manager and/or their respective representatives shall be
settled in accordance with and subject to the provisions of
The Arbitration and Conciliation Act 1996, or any
statutory requirement, modification or re-enactment
thereof. Such Arbitration proceedings shall be held at
Mumbai or such other place as the Portfolio Manager
thinks fit. The Arbitration proceedings shall be conducted
in English.
Client can also login on SCORES (SEBI Grievances
handling website) and register his/her complaints, if any,
against the Portfolio Manager on www.sebi.gov.in.
18. GENERAL
The Portfolio Manager and the client can mutually agree
to be bound by specific terms through a written two-way
agreement between themselves in addition to the
standard agreement.
Approved by the Directors of Avendus Wealth ManagementPrivate Limited
SignatureMr. Ranu Vohra
Mr. George Mitra
SR. No. Name of the Director
1
2
Sd/-
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