Investor Charter: Alternative Investment Fund

Vision

To develop the Alternative Investment Fund industry on professional and ethical lines and maintain high standards of governance and transparency.

Mission

• ·Maintain high professional and ethical standards within the AIF industry
• ·Comply with all applicable regulations and co-operate with the regulators in all aspects of AIF activity
• ·Act in a fiduciary capacity towards investors

• ·Raising capital from domestic and global investors
• ·Investing in portfolio companies in accordance with the investment strategy stated in the fund documents, with the objective of generating positive returns for stakeholders including investors
• ·Distributing returns to investors as set out in the fund documents

Onboarding

• ·Sharing the Private Placement Memorandum
• ·Completing investor KYC and registering it with the KYC Registration Agencies
• ·Sharing copies of the fund documents
• ·Entering into the contribution agreement

Investor consent for material changes

Consent is obtained for a change in the sponsor or manager of the AIF, a change in control of either, material changes to the terms of the Private Placement Memorandum covering the term of the fund, the investment strategy or an increase in fees and charges, and for winding up a fund or scheme before its tenure expires.

Financial information

• ·Net Asset Value of the fund or scheme
• ·Financial information of investee companies
• ·Information on the performance of the scheme or fund

Material risk disclosures

• ·Any inquiries or legal actions by legal or regulatory bodies in any jurisdiction
• ·Any material liability arising during the tenure of the fund
• ·Any breach of the Private Placement Memorandum, any agreement with the investor, or any other fund document
• ·Any conflict of interest
• ·Portfolio risks including concentration, foreign exchange, leverage, realisation, strategy and reputation risk, and extra-financial risks such as social and corporate governance risk, at both fund and investee company level

Non-material changes

Investors are informed of non-material changes such as bank account details, the address of the AIF, its manager or sponsor, and contact details including email and telephone.

Grievance redressal

Redressal of investor complaints received directly, and of complaints received through SEBI or SCORES.

Valuation

• ·Valuation of investments by a Category I or II AIF: at least once every six months. This may be extended to once a year with the approval of investors holding 75 percent by value of investment
• ·Disclosure of NAV for a Category III AIF: quarterly for a close ended fund, monthly for an open ended fund

Transparency

• ·Financial information of investee companies: within 180 days of the year end for Category I and II, or earlier if the fund documents require. Within 60 days of the quarter end for Category III
• ·Material risks, and financial, risk management, operational, portfolio and transactional information regarding fund investments: disclosed periodically
• ·Fees ascribed to the manager or sponsor, and fees charged to the AIF or any investee company: disclosed periodically
• ·Inquiries or legal actions by legal or regulatory bodies, material liabilities arising during the tenure, and breaches of the Private Placement Memorandum or investor agreements: as and when they occur
• ·Conflicts of interest in any transaction: as and when they arise or appear likely to arise
• ·Changes to the terms of the Private Placement Memorandum or fund documents: on a consolidated basis within one month of each financial year end

Complaints

• ·Response to a complaint received from an investor: within 30 days of receipt
• ·Redressal of a complaint received through SEBI or SCORES: within 30 days of receipt

• ·Alternative Investment Funds are required to redress all investor complaints in a timely manner
• ·The AIF, by itself or through its manager or sponsor, lays down a procedure for resolving disputes between investors and the AIF, manager or sponsor, through arbitration or another mechanism mutually agreed with investors
• ·Investors may also approach SEBI through the SCORES platform. On receipt of a complaint SEBI takes the matter up with the AIF
• ·Complaints may be sent to the Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, G Block, Bandra Kurla Complex, Bandra East, Mumbai 400051

Inform and educate yourself

• ·Read all fund documents thoroughly, including the Private Placement Memorandum, the contribution agreement, sales literature and newsletters, and understand the product
• ·Consider carefully all investment risks, fees and other factors detailed in those documents
• ·Satisfy yourself that the proposed investment meets your investment objective and matches your risk appetite
• ·Review portfolio holdings, account statements and transaction confirmations regularly, so you are aware of all transactions and the securities you are invested in

Keep your information current

• ·Provide complete and accurate information in your KYC documents, including financial and income status
• ·Update KYC information promptly when it changes

Abide by the contribution agreement

Read and understand the agreement you are entering into with the Alternative Investment Fund and abide by its terms. Investment terms are not a guarantee of future performance or returns.

Use the right intermediaries and advisors

Consider carefully the validity and reliability of investment information from all sources, particularly unsolicited information obtained over the internet.

Maintain confidentiality

Do not disclose material non-public information received by virtue of being an investor in the fund, except as the fund documents permit.