SEBI-Registered Investment Advisor Disclosures

Investor Charter in Respect of Moneyvesta Capital Services Private Limited

1. VISION AND MISSION STATEMENTS FOR INVESTORS

   • VISION
     Invest with knowledge & safety.
   • MISSION
     Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

2. Details of business transacted by the Investment Adviser with respect to the investors

   • To enter into an agreement with the client providing all details including fee details, aspect of Conflict of interest disclosure and maintaining confidentiality of information.
   • To do a proper and unbiased risk – profiling and suitability assessment of the client.
   • To conduct audit annually.
   • To disclose the status of complaints in its website.
   • To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI regional/local Office details in its website.
   • To employ only qualified and certified employees.
   • To deal with clients only from official number
   • To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.
   • To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers
   • Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by investment adviser.

3. Details of services provided to investors (No Indicative Timelines)

   • Onboarding of Clients
     • Sharing of agreement copy
     • Completing KYC of clients
   • Disclosure to Clients
     • To provide full disclosure about its business, affiliations, compensation in the agreement.
     • To not access client’s accounts or holdings for offering advice.
     • To disclose the risk profile to the client.
     • To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.
     • To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.
     • To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.
     • To treat all advisory clients with honesty and integrity.
     • To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.
     • To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services.
     •  To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.
     •  To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines.

4. Details of grievance redressal mechanism and how to access it

   1. Investor can lodge complaint/grievance against Investment Adviser in the following ways:
      Mode of filing the complaint with investment adviser
      In case of any grievance / complaint, an investor may approach the concerned Investment Adviser who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.
      Mode of filing the complaint on SCORES or with Investment Adviser Administration and Supervisory Body (IAASB)
      1. SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (SEBI SCORES portal)
         Two level review for complaint/grievance against investment adviser:
         • First review done by designated body (IAASB)
         • Second review done by SEBI
      2. Email to designated email ID of IAASB
   2. If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.
   3. With regard to physical complaints, investors may send their complaints to:
      Office of Investor Assistance and Education,
      Securities and Exchange Board of India,
      SEBI Bhavan, Plot No. C4-A, ‘G’ Block,
      Bandra-Kurla Complex, Bandra (E),
      Mumbai – 400 051

5. Rights of investors

   • Right to Privacy and Confidentiality
   • Right to Transparent Practices
   • Right to fair and Equitable Treatment
   • Right to Adequate Information
   • Right to Initial and Continuing Disclosure – Right to receive information about all the statutory and regulatory disclosures.
   • Right to Fair & True Advertisement
   • Right to Awareness about Service Parameters and Turnaround Times
   • Right to be informed of the timelines for each service
   • Right to be Heard and Satisfactory Grievance Redressal
   • Right to have timely redressal
   • Right to Suitability of the Financial Products
   • Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
   • Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
   • Additional Rights to vulnerable consumers
   • Right to get access to services in a suitable manner even if differently abled
   •  Right to provide feedback on the financial products and services used
   •  Right against coercive, unfair, and one-sided clauses in financial agreements

6. Expectations from the investors (Responsibilities of investors)

   
   
   • Do’s
     1. Always deal with SEBI registered Investment Advisers.
     2. Ensure that the Investment Adviser has a valid registration certificate.
     3. Check for SEBI registration number.
        Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:
        SEBI list of registered Investment Advisers
     4. Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.
        You may make payment of advisory fees through Centralised Fee Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism.
     5. Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
     6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
     7. Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
     8. Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
     9. Be vigilant in your transactions.
     10. Approach the appropriate authorities for redressal of your doubts / grievances.
     11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.
     12. Always be aware that you have the right to exit the service of an Investment Adviser
     13. Always be aware that you have the right to seek clarifications and clear guidance on advice
     14. Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
     15. Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.
   • Don’ts
     1. Don’t fall for stock tips offered under the pretext of investment advice.
     2. Do not provide funds for investment to the Investment Adviser.
     3. Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don’t let greed overcome rational investment decisions.
     4. Don’t fall prey to luring advertisements or market rumors.
     5. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
     6. Don’t take decisions just because of repeated messages and calls by Investment Advisers.
     7. Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
     8. Don’t rush into making investments that do not match your risk-taking appetite and investment goals.
     9. Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.

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Company Disclosures

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. 

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Investor Grievance Redressal

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

   Prashant Kumar

   Email

   [email protected]

   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 [email protected] 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 the SEBI SCORES portal, or you may also write to any of the offices of SEBI. SCORES may be accessed through the SCORES mobile application on Google Play. “SCORES” is a centralized web-based complaints redress system launched by SEBI.
   Nodal SEBI Office
   NBCC Complex, Office Tower-1,
   8th Floor, Plate B, East Kidwai Nagar,
   New Delhi – 110023

   SEBI Head Office
   Plot No. C4-A, “G” Block,
   Bandra-Kurla Complex, Bandra (East),
   Mumbai-400051, Maharashtra
7. If your complaint is not resolved on SCORES portal, you can start the dispute resolution process through the SMART 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.

Investor Grievance Escalation Matrix

Below is the escalation matrix table. It specifies the designated contact persons and their details to ensure a smooth & timely process to solve your concerns.

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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 United Nations Security Council consolidated sanctions list.
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 paid to transactions which exceeds these limits. 
4. 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. 
5. 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. 
6. These records shall be preserved for a period of five years from the date of transaction with such client.
7. The following transactions shall be monitored at all times:
8. all cash transactions of the value of more than ten lakh rupees or its equivalent in foreign currency;
9. 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;
10. 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;
11. 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. 
12. 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: Financial Intelligence Unit–India website

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.: 9205522941

Email Id: [email protected]

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

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SEBI Annual Audit Status

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