FUNCTIONS OF IA

Functions of IA

Functions, obligations, duties, and responsibilities of the Investment Adviser (including principal officer and all persons associated with the investment advice) include the following, among others to discharge the Investment advisory services, subject to this agreement:

(a) Fiduciary duty

We shall act in a fiduciary capacity towards you, always and shall disclose all conflicts of interests as and when they arise.

(b) Restricted Consideration

We shall not receive any consideration by way of remuneration or compensation or in any other form from any person other than the client being advised, in respect of the underlying products or securities for which advice is provided.

(c) Arms-Length activities

We shall maintain an arms-length relationship between our activities as an investment adviser and other activities.

(d) Segregation of IA services

We, in case of engaging in activities other than investment advisory services, as may be permitted by the Regulatory mandates, shall ensure that the investment advisory services are clearly segregated from all our other activities, in the manner as prescribed under the IA Regulations.

(e) Disclosure of conflict of interest

We shall ensure that in case of any conflict of interest of the investment advisory activities with other activities, such conflict of interest shall be disclosed to you.

(f) Non-disclosure of confidential information

We shall not divulge any confidential information about you, which has come to our knowledge, without taking your prior permission, except where such disclosures are required to be made in compliance with any law for the time being in force.

You hereby agree, acknowledge, consent and permit to the processing and use of your confidential information including personal data and financial data, by us including our third-party vendors, as far as it is necessary for the performance of our functions, obligations, and responsibilities, towards providing services, herein.

(g) Restricted Transactions contrary to advice given

We, the investment advisor shall not enter transactions on our own account which is contrary to our advice given to you for a period of fifteen days from the day of such advice.

Provided that during the period of such fifteen days, if we are of the opinion that the situation has changed, then we may enter into such a transaction on our own account after giving such revised assessment to you at least 24 hours in advance of entering into such transaction.

You agree that the advice given to you is subject to a specific set of factors including the client-profile, risk-profile, goals, market conditions and others, and such set of factors differ for different persons including us. Therefore, you agree to consent and permit that we may enter into transactions on our own account which may be contrary to our advice given to you. In case, you need any confirmation or clarification or have any objection in our such transactions or holding or position, you shall notify us immediately.

(h) KYC compliance

We, the investment advisor shall follow Know Your Client (‘KYC’) procedure as specified by the Board from time to time.

(i) Code of Conduct

We undertake to abide by Code of Conduct as specified in Third Schedule of the IA Regulations – contained as in Schedule.

(j) Restricted Transactions on own account

We shall not act on our own account, knowingly to sell securities or investment products to or purchase securities or investment product from a client.

(k) Prior approval for change in control

We shall take prior approval from the Board, in case of change in control of our entity.

(l) Submission of Information

We shall furnish to the Board, information and reports as may be specified by the Board from time to time.

(m) Compliance with Certification and Qualification requirements

We shall ensure compliance with the certification and qualification requirements as specified u/r 7 of IA Regulations, at all times.

These include the qualification and certification requirement for an individual investment adviser or principal officer of a non-individual investment adviser registered under the IA Regulations, as the case may be, and the persons associated with investment advice.

(n) Compliance with Regulatory mandates

We shall ensure compliance with the Regulatory mandates.

(o) Compliance with Eligibility criteria

We shall ensure compliance with the eligibility criteria as specified under the IA Regulations at all times.

(p) Risk profiling and suitability

We follow a set process of risk profiling, risk assessment and suitability analysis, as mandated u/r 16 and 17 of IA Regulations and other regulatory mandates, including your risk capacity and risk aversion.

(q) Reports to clients

We shall provide reports to my / our client on potential and current investments.

(r) Maintenance of records

We shall maintain the records, as specified u/r 19(1) of IA Regulations and related books of accounts including client accounts and data.

(s) Audit as per the IA Regulations

We shall conduct yearly audit u/r 19(3) of IA Regulations, in respect of compliance with the IA Regulations.

Disposal of complaints Annual
Year Carried forward Received Resolved Pending
2019 - 2020 0 0 0 0
2020 - 2021 0 0 0 0
2021 - 2022 0 0 0 0
Grand Total 0 0 0 0
Contact us directly at shabbir@sensageonline.com for assistance with any queries, complaints or grievances. We will ensure your grievance is resolved within 30 days. If you feel that your grievance is not redressed satisfactorily, you may lodge a complaint with SEBI through the Scores website or the SEBI Scores app for Android or iOS.
Disposal of complaints Monthly
Month Carried forward Received Resolved Pending
February-2021 0 0 0 0
March-2021 0 0 0 0
April-2021 0 0 0 0
May-2021 0 0 0 0
June-2021 0 0 0 0
July-2021 0 0 0 0
August-2021 0 0 0 0
September-2021 0 0 0 0
October-2021 0 0 0 0
November-2021 0 0 0 0
December-2021 0 0 0 0
January-2022 0 0 0 0
Grand Total 0 0 0 0
Contact us directly at shabbir@sensageonline.com for assistance with any queries, complaints or grievances. We will ensure your grievance is resolved within 30 days. If you feel that your grievance is not redressed satisfactorily, you may lodge a complaint with SEBI through the Scores website or the SEBI Scores app for Android or iOS.
Disposal of complaints Current Month
Received From Pending- last month Received Resolved Total pending Pending > 3M Avg. resolution time
Investors 0 0 0 0 0 0
SEBI Sources 0 0 0 0 0 0
Other Sources 0 0 0 0 0 0
Grand Total 0 0 0 0 0 0

Disposal of complaints Monthly

Disposal of complaints Annual

Contact us directly at shabbir@sensageonline.com for assistance with any queries, complaints or grievances. We will ensure your grievance is resolved within 30 days. If you feel that your grievance is not redressed satisfactorily, you may lodge a complaint with SEBI through the Scores website or the SEBI Scores app for Android or iOS.
Investor Charter
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.

Details of business transacted by the Research Analyst with respect to the investors

1. 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.
2. To do a proper and unbiased risk – profiling and suitability assessment of the client.
3. To obtain registration with Know Your Client Registration Agency (KRA) and Central Know Your Customer Registry (CKYC).
4. To conduct audit annually.
5. To disclose the status of complaints in its website.
6. 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.
7. To employ only qualified and certified employees.
8. To deal with clients only from official number.
9. To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.

Details of services provided to investors (No Indicative Timelines)

● Onboarding of Clients

1. Sharing of agreement copy
2. Completing KYC of clients

● Disclosure to Clients

1. To provide full disclosure about its business, affiliations, compensation in the agreement.
2. To not access client’s accounts or holdings for offering advice.
3. To disclose the risk profile to the client.

● To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client

Details of grievance redressal mechanism and how to access it

1. In case of any grievance / complaint, an investor should approach the concerned Investment Adviser and shall ensure that the grievance is resolved within 30 days.
2. If the investor’s complaint is not redressed satisfactorily, one may lodge a complaint with SEBI on SEBI’s 'SCORES' portal which is a centralized web based complaints redressal system. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates tracking the status of the complaint.
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.

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.
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.
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.

● 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 and demat accounts with the Investment Adviser.