Disclosure

About the Company:

Moneyvesta Capital Services Private Limited (herein referred to as the Company) is a Private Limited Company registered under the Companies act, 2013, having its registered office at 514-B, Unitech Arcadia, Unitech Arcadia, South City-II, South City, Gurgaon, Haryana, 122018. The Company was incorporated on 05th April, 2023.

The Company got registered with SEBI as an investment adviser on 24th August, 2023 and is valid till perpetual (Reg No: INA000018407). 

About the Directors:
The details of the Directors are as follows:

1. Mr. Manasvi Garg holds a B-Tech. in civil engineering from IIT Kanpur and an MBA in International Management from MDI Gurgaon. He's a CFA Charterholder and previously worked as an equity research analyst at JP Morgan. In March 2023, he founded Moneyvesta Capital Services Private Limited, venturing into entrepreneurship in the finance industry.

2. Ms. Bhawna Bhatia has a Bachelor's in Information Technology from Delhi College of Engineering and has cleared two levels of the CFA program. She possesses a diverse professional background, having worked at Sapient, Accenture, and currently at Veracy Consulting. Her experience spans business analysis, functional design, development, and regulatory reporting management in the Energy Trading and Risk Management domain.

3. Mrs. Kavita Jindal’s academic journey includes distinctions in matriculation exams and a diploma in Electronics and Communication Engineering. She has been the sole proprietor at Jindal Infrastructure since 2015, showcasing her experience in infrastructure management.

About Business activities:
The Company offers services related to investment advisory, personal finance consultancy, financial planning, advising on investments products, financial products such as mutual funds, bonds, commercial deposits, stocks and other financial products and securities to the investors and corporates.  The advice will be provided on mix of stocks, mutual funds, insurance etc. on basis of risk profiling and suitability of the client. The Company primarily focus on high-risk category clients such as corporates, high net worth individuals, salaried individuals with high disposable incomes, etc. 

Disciplinary History:
There are no outstanding litigations or no disciplinary history against the Company and its Directors.

Disclosure about conflict of interest:
The Company is registered with AMFI as a mutual fund distributor with ARN-269314. It is engaged with various AMCs for providing services related to distribution of Mutual Fund.

The Company will receive commission for distribution of mutual funds of the AMCs with which the Company is associated.

Disclosure about holding position of the Company and the Directors:
The Company and the Directors may have a holding position in the same financial products and securities which are subject matter of advice given to the clients. 

Other Disclosure: 
The Company shall provide execution services only through direct schemes /products in the market. Mr. Manasvi Garg, Principal Officer and the person associated with the Investment Advice shall be responsible for providing implementation services. However, the Company will not receive any consideration for the execution services.  

The distribution and implementation / execution services shall be carried on through a separate identified department/division and shall be arm’s length with all the advisory clients. The compliance requirements for client level segregation will be followed by the Company at all times. 

REDRESSAL OF GRIEVANCE

At Moneyvesta, we place the utmost importance on addressing customer concerns and take every grievance seriously. 

1. If you are not satisfied with our services and would like to lodge a complaint, we would request you to first talk to our representative / consultant from the Investment Advisers Department who is your point of contact. You can discuss with him / her, and be rest assured that your complaint will be resolved on best efforts within 15 working days.

2. You can also email or talk to the representative / consultant via telephone. The contact no. is

      Name: Rachna Ritu

      Email: rachna.ritu@moneyvesta.com

      Phone: +91-9205533879

3. You may also write a letter with your complaint and post it at the below mentioned address: 514-B, Unitech Arcadia, Unitech Arcadia, South City-II, South City, Gurgaon, Haryana, 122018

4. We will try to resolve your complaint within 15 to 30 working days. The first step is for us to be clear about the nature of your complaint, and to identify what we can do to resolve the issue. When we have finished our investigations into your complaint, we will be in touch to provide you with a full response to your complaint.

5. If you are not still not satisfied with the response or the handling of your complaint by our representative / consultant, you can approach and write an email to Mr. Manasvi Garg, Principal Officer and Director, at manasvi.garg@moneyvesta.com with complete details. Mr. Manasvi Garg will get in touch with you at the earliest and try to resolve your complaint as soon as possible.

6. If your complaint is not resolved within a period of one month, you may lodge your complaint to the regulator - The Securities and Exchange Board of India (SEBI) at https://scores.sebi.gov.in/ or you may also write to any of the offices of SEBI. SCORES may be accessed thorough SCORES mobile application as well, same can be downloaded from below link: https://play.google.com/store/apps/details?id=com.ionicframework.sebi236330. ‘SCORES’ is a centralized web-based complaints redress system launched by SEBI.

Nodal SEBI office:                                                                               SEBI Head Office:

NBCC Complex, Office Tower-1,                                                      Plot No. C4-A, ‘G’ Block

8th Floor, Plate B, East Kidwai Nagar,                                            Bandra-Kurla Complex, Bandra (East),

New Delhi – 110023                                                                           Mumbai-400051, Maharashtra

7. If your complaint is not resolved on SCORES portal, you can start the dispute resolution process through the ODR Portal. Your attention is drawn to the SEBI circular no. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023, on “Online Resolution of Disputes in the Indian Securities Market”. A common Online Dispute Resolution Portal (“ODR Portal”) which harnesses conciliation and online arbitration for resolution of disputes arising in the Indian Securities Market has been established. The link for the platform is https://smartodr.in/login.

September 2024 Complaints

*  Inclusive of complaints of previous years resolved in the current year.

# Inclusive of complaints pending as on the last day of the year.

^ Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.

Trend of monthly disposal of complaints

*  Inclusive of complaints of previous years resolved in the current year.

# Inclusive of complaints pending as on the last day of the year.

^ Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.

Trend of annual disposal of complaints

MLA (ANTI MONEY LAUNDERING) POLICY

Introduction

This policy is framed and adopted as a requirement by SEBI under the Prevention of Money Laundering Act, 2002 (“PMLA”). The policy provides a framework with respect to anti money laundering measures to be taken by Moneyvesta Capital Services Private Limited (herein referred to as the Company), as a SEBI registered Investment Adviser. 

Objective of the PMLA Policy

The objective of the PMLA policy are as follows:

1. To prevent the Company from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.
2. Create awareness and provide clarity on KYC standards and AML measures.
3. To have a proper Client Due Diligence (CDD) process before registering clients.
4. To monitor and report suspicious transactions.
5. To monitor / maintain records of all cash transactions done by the client of the value of more than Rs.10 lacs.

Client Due Diligence (CDD) Process

As a part of Client Due Diligence process, the Company will do the following:

1.  Maintain a record of Know Your Customer (KYC) documents (i.e., valid identity proof and address proof) obtained from all the client at the time of on boarding the clients.
2. In order to verify the genuineness of the clients, to speak with the clients before proceeding with any advisory services. 
3. The records between the client and the Company to be maintained in proper order. 

Policy for Acceptance of Client

The Company will ensure that-

1. No account shall be opened in fictitious name or on an anonymous basis. 
2. No account will be opened if the fee for services is offered by the client in cash. 
3. No account is opened where the Company is unable to apply appropriate CDD measures/ KYC policies. This shall apply to cases where the information provided to the Company is suspected to be non - genuine, or there is perceived non - cooperation of the client in providing full and complete information.
4. It will be ensured that the identity of the client does not match with any person having known criminal background or is not banned in any other manner or is included in the list of individuals and entities which are subject to various sanction measures such as freezing of assets/accounts, denial of financial services etc., as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs) can be accessed at its website at http://www.un.org/sc/committees/1267/consolist.shtml.
5. Each client shall be classified in low or medium or high risk categories depending upon the risk perception. Such risk may be arrived considering various factors of risk perception of the client having regard to:-
   1.clients’ location (registered office address, correspondence addresses and other addresses if applicable),
   2.nature of business activity, trading turnover etc. and
   3. manner of making payment for transactions undertaken.
6. Clients of Special Category (CSC) require higher degree of due diligence and regular update of Know Your Client (KYC) profile.
   1. Non - resident clients;
   2. High net-worth clients;
   3. Trust, Charities, Non-Governmental Organizations (NGOs)and organizations receiving donations;
   4. Companies having close family shareholdings or beneficial ownership;
   5. Politically Exposed Persons (PEP);
   6. Companies offering foreign exchange offerings;
   7. Clients in high-risk countries where existence / effectiveness of money laundering controls is suspect;
   8. Non face to face clients;
   9. Clients with dubious reputation as per public information available etc.

Suspicious Transactions

1. The Company will ensure that that appropriate steps are taken to enable suspicious transactions to be recognized based on the circumstances like-
2. Clients whose identity verification is difficult or client is not ready to cooperate. 
3. Where the source of funds of the clients is not clear or not keeping with clients apparent standing/ business activity;
4. Substantial increases in business without apparent cause;
5. Clients based in high risk jurisdictions;
6. Clients transferring large sums of money to or from overseas locations with instructions for payment in cash;
7. Attempted transfer of investment proceeds to apparently unrelated third parties;
8. Unusual transactions by CSCs and businesses undertaken by offshore banks/financial services, businesses reported to be in the nature of export- import of small items.
9. In the event of any suspicious transaction, the Company will make a report based on the reference to the clients, transactions and the nature/ reason of suspicion. The report will be submitted to the Director, Financial Intelligence Unit-India. 
10. In the event where the transactions are abandoned or aborted by clients on being asked to give some details or to provide documents, the Company will report all such attempted transactions in Suspicious Transaction Reports, even if not completed by clients, irrespective of the amount of the transaction. 

Monitoring of transactions

1. The transactions shall be monitored in the following manner:
2. Special attention shall be paid to all complex unusually large transactions / patterns which appear to have no economic purpose. 
3. Internal threshold limits for each class of client accounts shall be defined and special attention shall be 
4. paid to transactions which exceeds these limits. 
5. The background including all documents/office records /memorandums/clarifications sought pertaining to such transactions and purpose thereof shall also be examined carefully and findings shall be recorded in writing. 
6. Further the findings, records and related documents shall be made available to auditors and also to SEBI/stock exchanges/FIUIND/ other relevant Authorities, during audit, inspection or as and when required. 
7. These records shall be preserved for a period of five years from the date of transaction with such client.
8. The following transactions shall be monitored at all times:
9. all cash transactions of the value of more than ten lakh rupees or its equivalent in foreign currency;
10. all series of cash transactions integrally connected to each other which have been individually valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the monthly aggregate exceeds an amount of ten lakh rupees or its equivalent in foreign currency;
11. all cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine or where any forgery of a valuable security or a document has taken place facilitating the transactions;
12. all suspicious transactions whether or not made in cash and by way of cheques, pay orders, travellers’ cheques, demand drafts, loan and advances, money transfer or remittances in favour of own clients or non-clients from India or abroad and to third party beneficiaries in India or abroad, credits or debits into or from any non-monetary accounts such as d-mat account. 
13. Periodic review of the existing account shall be conducted to ensure that no existing accounts are linked to any of the entity or individual included in the list by Security Council Committee. Any resemblance found to be reported to SEBI and FIU-IND. 

Record Keeping and Retention of Records

1. In case of suspicious transactions, the Company will -
2. ensure compliance with the record keeping requirements contained in the SEBI (Investment Adviser) Regulations, 2013, PMLA and other relevant legislation.
3. maintain such records as are sufficient to permit trail of individual transactions (including the amount and types of currencies involved, if any) so as to provide, if necessary, evidence for prosecution of any criminal behaviour.
4. retain the following information for the accounts of the clients in order to maintain a satisfactory audit trail so that in case of any suspected drug related or other laundered money or terrorist property, the competent investigating authorities can trace through the audit trail for reconstructing a financial profile of the suspected account:
5. the beneficial owner of the account; and
6. for selected transactions, the origin of funds, the form in which the funds were offered or withdrawn, e.g. cheques, demand drafts etc, the identity of the person undertaking the transaction, the destination of the funds and, the form of instruction and authority. 
7. Record of the transactions shall be preserved and those transactions of a suspicious nature shall be reported to the Director, FIU-IND. 
8. Record of information related to transactions, whether attempted or executed, which are reported to the Director, FIU‐IND and shall be maintained and preserved for a period of five years from the date of the transaction with the client. In situations where the records relate to on-going investigations or transactions which have been the subject of a suspicious transaction reporting, they shall be retained until it is confirmed that the case has been closed.

Information to be maintained

Following information in respect of all transactions referred to Clause V.f of this policy shall be maintained:

1. the nature of the transactions;
2. the amount of the transaction and the currency in which it is denominated;
3. the date on which the transaction was conducted; and
4. the parties to the transaction. 

Reporting to Financial Intelligence Unit-India

In terms of the PML Rules, the Company will report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at the following address: 

Director,

FIU-IND, Financial Intelligence Unit-India,

6th Floor, Hotel Samrat, Chanakyapuri, New Delhi-110021.

Website: http://fiuindia.gov.in

Appointment of Principal Officer and Designated Director:

To ensure effective discharge of our legal obligations, to report suspicious transactions to the authorities and overall supervision and compliance, the following shall be the “Principal Officer” and “Designated Director” who would act as a central reference point for the identification and assessment of potentially suspicious transactions and in facilitating onward reporting of suspicious transactions to FIU:

Name: Manasvi Garg

Designation: Director

Contact No.: 9999272055

Email Id: gargmanasv@gmail.com

Rights, Obligation and Responsibilities of Principal Officer:

1. The principal office shall have all time access to customer identification data and other CDD information.
2. The principal officer shall have complete independence and authority to access.
3. The principal officer shall ensure that the PMLA Policy framework is implemented effectively.
4. The principal officer shall ensure data generated on FIU on suspicious transaction is regularly and promptly downloaded to analyze, identify and report transactions of suspicious nature to FIU-IND directly.
5. The principal officer shall ensure that the records and information in relation to all client and transaction are available on timely basis to the competent authority.
6. The principal officer shall ensure that there is a prompt response to any request for information, including KYC related information and records maintained by COMPANY, made by the regulators, FIU-IND and other statutory authorities. 
7. The principal officer shall ensure all concerned staff is regularly updated regarding any changes / additions / modifications in PMLA provisions.

Rights, Obligations and Responsibilities of Designated Director:

1. The Designated Director should ensure that all the records are maintained as mentioned in this Policy. 
2. In case where the Designated Director fails to perform his duties, he shall be penalised and appropriate action may be taken against him.

Employees’ Hiring/ Employee’s Training/ Investor Education:

The COMPANY will-

1. have adequate screening procedures in place to ensure high standards when hiring employees. 
2. have ongoing employee training programme so that the members of the staff are adequately trained in Anti-Money Laundering standards (AML) and Combating the Financial of Terrorism (CFT) procedures.  

Review of Policy
The policy shall be reviewed from time to time as and when required changes will be implemented as per the applicable rules, laws, acts and regulations.

 Smart ODR

Terms of Use for Moneyvesta Capital Services Private Limited (MCSPL)

Welcome to the official website of Moneyvesta Capital Services Private Limited, hereafter referred to as "MCSPL." Your access and use of this website are governed by the following terms and conditions. It is imperative that you carefully review these terms to understand your rights and obligations while navigating our site. By accessing this website, you acknowledge your consent to be bound by these terms. If any part of these terms is not agreeable to you, we kindly request that you exit the site without delay.

1. Jurisdiction and Copyright Protection: 

a. All disputes arising out of or in connection with the use of this website shall be subject to the exclusive jurisdiction of the competent courts located in Gurgaon, India, and you expressly consent to such jurisdiction. 

b. All content, including text, graphics, images, videos, logos, trademarks, and other materials displayed on this website, is protected by Indian and international copyright laws, intellectual property laws, and treaties. All rights to the content are expressly reserved, and unauthorized reproduction, distribution, or usage is strictly prohibited. 

c. Visitors and users are granted a limited, non-exclusive, and revocable license to access and use the content for personal, non-commercial purposes only. Any other use of the content, including reproduction, distribution, or adaptation, is expressly prohibited.

2. Non-Commercial Use: 

a. This website is intended for personal, non-commercial use. It is strictly prohibited to use any content or materials from this site for any commercial purposes, including but not limited to resale, public display, distribution, or any form of financial exploitation.

3. Vendor Software and Hardware: 

a. Certain sections of this website may utilize proprietary software and hardware that are the legal property of third-party vendors and licensors. You agree not to attempt to replicate, modify, reverse engineer, decompile, disassemble, or otherwise tamper with such software and hardware. Unauthorized access to, modification, or use of these components may lead to legal consequences, including civil and criminal penalties. 

b. Visitors are further prohibited from exporting, re-exporting, or transmitting software, technology, or any related information in violation of applicable export control laws and regulations.

4. Transaction Disclaimer: 

a. MCSPL acts as a facilitator for investment transactions, including those involving Asset Management Companies (AMCs). It is important to understand that AMCs reserve the right to refuse or not accept transactions if they have reasonable grounds of suspicion. However, the reason for refusal is not limited to this sole factor and may encompass other considerations as well. 

b. You expressly agree that neither AMCs nor MCSPL shall be held responsible for any non-execution, delays, or other issues related to the execution of transactions. 

c. Any loss, damage, or potential opportunity cost arising from such non-execution or delays shall not be the responsibility of AMCs or MCSPL. It is your responsibility as an investor to verify the status of your transactions and to address any concerns directly with the respective AMC or investment service provider.

5. No Investment Advice: 

a. All information and content presented on this website, regardless of its form, is intended solely for educational and illustrative purposes only. It is not intended to be, nor should it be construed as, financial, investment, tax, legal, or any other form of professional advice or an endorsement of any specific financial product. 

b. Visitors are strongly advised to consult with their own financial advisor, tax advisor, legal counsel, or relevant experts before making any financial, investment, legal or tax decisions. MCSPL explicitly disclaims any responsibility for losses or consequences resulting from actions taken based on the information presented on this website.

6. Accuracy of Information: 

a. MCSPL is committed to providing accurate and up-to-date information on this website. The information is sourced from reputable and reliable sources. However, you acknowledge that the financial landscape is subject to rapid changes and market volatility. 

b. MCSPL does not warrant the accuracy, completeness, or reliability of the information presented on the website. You are encouraged to independently verify any information before making any financial or investment decisions.

7. Modification of Terms: 

a. MCSPL reserves the exclusive right to modify, amend, or otherwise change these terms and conditions at its sole discretion. Such changes may occur without prior notice to visitors. 

b. Visitors are strongly advised to regularly review these terms and conditions each time they access the website to stay informed about any changes. Your continued use of the website constitutes your acceptance of the updated terms and conditions.

8. Third-Party Links: 

a. This website may contain links to third-party websites, resources, or content. These links are provided for your 

convenience. MCSPL does not assume any responsibility for the content, accuracy, legality, or accessibility of these external links. The presence of such links does not imply endorsement, affiliation, or sponsorship by MCSPL. 

b. You acknowledge that by clicking on third-party links, you are leaving the MCSPL website and are subject to the terms and policies of the linked websites. MCSPL assumes no responsibility for the privacy policies of external links, as they fall outside the scope of our own privacy policy. We recommend reviewing them independently.

9. Acceptance of Terms: 

a. By accessing and using this website, you explicitly acknowledge and accept these terms and conditions. If you do not agree with any part of these terms, it is your responsibility to exit the site immediately and refrain from further use.

10. No Liability Clause: 

a. To the fullest extent permitted by the laws of India, MCSPL explicitly disclaims any liability for any economic loss, capital loss, savings loss, data loss, business loss, lost management time loss, or any indirect or consequential loss arising from data usage or access to the website. 

b. This disclaimer includes but is not limited to loss of profits, loss of business opportunities, loss of data, and loss of reputation. MCSPL does not assume any responsibility for any consequences arising from the use of its website. c. All directors, officers, employees, agents, affiliates, subsidiaries, subcontractors, and sales partners of MCSPL are also disclaimed from any liability for any damages or losses, whether direct or indirect, arising from the use of this website.

11. Past Performance Disclaimer: 

a. Visitors are reminded that past performance of investments, financial products, and securities is not indicative of future results. No guarantees or assurances are made regarding the future performance or success of any investments. 

b. It is the sole responsibility of the investor to exercise caution, perform thorough due diligence, and consult with relevant experts, such as financial advisors, tax advisors, and legal counsel, before making any investment decisions based on the information presented on the website.

12. Privacy Policy: 

a. MCSPL values your privacy. Please review our Privacy Policy to understand how we collect, use, and protect your personal information.

By accessing and using the MCSPL website, you are bound by and agree to abide by these terms and conditions. Your use of the website indicates your understanding and acceptance of these terms and conditions. It is recommended to review these terms periodically to ensure you are informed about any changes or updates. If you do not agree with any part of these terms and conditions, please exit the site immediately.

 13. Force Majeure

MCSPL shall not be liable for delays or errors occurring by reason of circumstances beyond its control, including but not limited to acts of civil or military authority, national emergencies, work stoppages, fire, flood, catastrophe, acts of God, pandemic, epidemic, insurrection, war, riot, or failure of communication or power supply. In the event of equipment breakdowns beyond its control, it shall take reasonable steps to minimize service interruptions but shall have no liability with respect thereto

Moneyvesta Capital Services Private Limited (MCSPL) Refund Policy

1. Introduction

This Refund Policy governs the management of fees and refunds at Moneyvesta Capital Services Private Limited (MCSPL). Our policy is designed to be fair and transparent, ensuring compliance with all applicable laws and regulations.

2. Fee Structure

MCSPL charges fees based on the service period and frequency as stipulated in the Investment Advisory (IA) agreement with our clients. This frequency may be monthly, quarterly, semi-annually, or annually, and fees may be levied either at the beginning or end of each period, as outlined in the IA agreement.

3. General Non-Refund Policy

As a general rule, MCSPL adheres to a 'Non-Refund Policy'. Fees once charged are non-refundable, except in specific circumstances detailed below regarding pre-mature termination of the IA agreement.

4. Refund on Pre-Mature Termination

In the event of a pre-mature termination of the IA Agreement by the client, the following refund conditions apply:

1. Refund for Unexpired Period: MCSPL will refund the fees for the unexpired period of the agreement.
2. Breakage Fee: MCSPL will retain a maximum breakage fee not greater than the fee for one quarter. This is to cover administrative costs and loss of revenue associated with the early termination.
3. Notification and Process: Clients must provide written notification for pre-mature termination. Upon verification and calculation, MCSPL will process the refund, deducting the applicable breakage fee, within 90 days.

5. Limitations and Conditions

The refund in the case of pre-mature termination is subject to the following limitations and conditions:

1. The client must be in compliance with all other terms of the IA agreement.
2. The refund request must adhere to the procedures outlined in this policy and the IA agreement.

6. Amendments

MCSPL reserves the right to amend this policy at any time. Such amendments will be effective immediately upon posting the updated policy on our website.

7. Contact Information

Clients with questions or who require clarification regarding this policy are encouraged to contact MCSPL at manasvi.garg@moneyvesta.com