Investor Charter for Portfolio Managers

1. Vision and Mission

Vision

To invest in a manner that respects the fact that the capital entrusted to us represents someone’s savings — and to ensure that every client understands what they own, what it costs and what can go wrong, before anything else.

Mission

• To provide portfolio management services with integrity, competence and transparency, in accordance with the SEBI (Portfolio Managers) Regulations, 2020 and all applicable circulars.
• To ensure that every client receives the Disclosure Document, the fee illustration and the client agreement before investing, and understands the risks disclosed in them.
• To keep client securities in the client’s own name, and client funds segregated, at all times.
• To report performance honestly, in the prescribed format, net of all fees and expenses, and never to represent an assured return.
• To resolve investor grievances promptly, and to publish our complaints record whether or not it flatters us.

2. Details of business transacted by the portfolio manager

Redberyl Investment Managers LLP is registered with the Securities and Exchange Board of India as a Portfolio Manager under the SEBI (Portfolio Managers) Regulations, 2020, bearing registration number INP000010238. The firm undertakes the management of portfolios of securities and funds on behalf of clients on a discretionary basis, in accordance with the client agreement executed with each client.

The portfolio manager:

• manages portfolios of listed equity and equity-related securities, debt securities, money-market instruments, units of mutual funds and other permitted securities, in accordance with the mandate agreed with each client;
• maintains client securities in a demat account opened in the name of the client, with a SEBI-registered depository participant, and under a custody arrangement with a SEBI-registered custodian;
• maintains client funds in a designated bank account operated in accordance with the Regulations;
• does not accept, hold or manage funds or securities other than in accordance with the Regulations and the client agreement.

3. Details of services provided to investors

3.1 On-boarding of clients

• Sharing of the Disclosure Document, the fee schedule with illustrations and the standard client agreement with every prospective client at least two days before the agreement is signed.
• Completion of KYC in accordance with SEBI and KRA requirements, including in-person verification where required.
• Execution of a written client agreement setting out the mandate, the investment approach, the fee option selected, the exit load, the reporting frequency and the risk disclosures.
• Mandatory offer of the direct on-boarding option, under which the client may engage the portfolio manager without any distributor and without any distribution commission being charged to the portfolio.
• Opening of a demat account in the client’s name and establishment of the custody arrangement before any investment is made.

3.2 Disclosures to clients

• The Disclosure Document, containing the fee structure, all risk factors, the audited financial statements of the portfolio manager, performance of the portfolio manager, related-party disclosures and the details of any pending litigation or regulatory action.
• An illustration of the fees and charges payable under each fee option, across a range of gain and loss scenarios.
• Disclosure of the hurdle rate and the high water mark applicable to any performance-linked fee.
• Disclosure of any conflict of interest, related-party transaction or arrangement material to the client relationship.

3.3 Portfolio management

• Investment of client funds and securities in accordance with the agreed investment approach and any restrictions specified by the client.
• Fair and equitable allocation of trades across client portfolios in accordance with the order allocation policy.
• Exercise of voting rights on securities held in client portfolios in accordance with the disclosed proxy voting policy.
• No investment of client funds in the portfolio manager’s own securities or in any manner prohibited by the Regulations.

3.4 Reporting to clients

• A report to every client, at intervals of not more than three months and at any time on request, containing: the composition and value of the portfolio; transactions during the period; dividend, interest and other receipts; expenses and fees charged; realised and unrealised gains and losses; and details of any default or material event.
• An annual audit of the client’s portfolio by an independent chartered accountant. The client may, at the client’s own cost, appoint a chartered accountant of the client’s choosing to audit the books relating to the client’s own transactions.
• Provision of statements required for the client’s tax filings.

3.5 Withdrawal, termination and no exit barriers

• Partial or full withdrawal in accordance with the client agreement, in cash or, where practicable and at the client’s election, by transfer of securities.
• Exit load, where charged, is capped by SEBI at 3% of the amount withdrawn in the first year from the date of investment, 2% in the second year, 1% in the third year, and nil thereafter.
• Termination of the agreement by either party in accordance with its terms, followed by settlement of the account and transfer of securities and funds without undue delay.
• No exit barriers are imposed beyond those expressly stated in the client agreement and permitted by the Regulations.

4. Rights of investors

• To receive the Disclosure Document and the client agreement before investing, and to have adequate time to consider them.
• To be on-boarded directly, without a distributor, and without any distribution commission being charged.
• To hold securities in a demat account in the investor’s own name, and to verify holdings independently with the depository.
• To receive periodic reports as described above, and to obtain a report on demand.
• To be informed of any material change in the investment approach, fee structure, key personnel or the regulatory standing of the portfolio manager.
• To impose reasonable restrictions on the mandate, recorded in writing.
• To withdraw or terminate in accordance with the agreement, subject only to the disclosed exit load.
• To have grievances redressed within the timelines set out below, and to escalate to SEBI through SCORES and thereafter to the ODR mechanism.
• To be treated fairly and without discrimination in the allocation of investment opportunities.

5. Grievance redressal mechanism

Investors may lodge a complaint with the portfolio manager by writing to compliance@redberyl.in, by post at the registered office, or by telephone on +91 97892 93087. Every complaint is acknowledged and tracked to closure.

Stage	Whom to approach	Timeline
Level 1 Client Servicing Desk	Write to invest@redberyl.in or call +91 97892 93087 during business hours.	7 working days
Level 2 Grievance Redressal Officer	If unresolved, escalate to Raunak Noah at compliance@redberyl.in.	14 working days
Level 3 Principal Officer	If still unresolved, write to O M Jaya Priya at jayapriya@redberyl.in.	21 working days
Level 4 SEBI SCORES 2.0	Lodge a complaint on the SEBI Complaint Redress System at scores.sebi.gov.in. SEBI toll-free helpline: 1800 22 7575 / 1800 266 7575.	As per SEBI timelines
Level 5 Online Dispute Resolution (SMART ODR)	If you remain dissatisfied, initiate conciliation or arbitration through the SEBI SMART ODR portal at smartodr.in.	As per ODR timelines

If the complaint is not resolved to the investor’s satisfaction, the investor may lodge it on the SEBI SCORES 2.0 portal at scores.sebi.gov.in, or call the SEBI toll-free helpline on 1800 22 7575 / 1800 266 7575. Thereafter, the investor may initiate dispute resolution through the Online Dispute Resolution portal at smartodr.in, in accordance with the SEBI circular on Online Resolution of Disputes in the Indian Securities Market.

Our monthly complaints data, in the format prescribed by SEBI, is published at Investor Complaints Data.

6. Expectations from investors

Investors should

• Read the Disclosure Document, the fee illustration and the client agreement carefully before signing, and ask questions about anything that is not clear.
• Verify the SEBI registration of the portfolio manager, and the APMI registration of any distributor involved.
• Provide complete and accurate KYC information, and update it promptly when it changes.
• Transfer funds only to the designated bank account of the portfolio manager.
• Read the periodic portfolio reports, and raise any discrepancy without delay.
• Understand the risk of the strategy chosen and the horizon it requires.
• Keep records of all documents and communications relating to the account.

Investors should not

• Rely on any promise, indication or implication of assured or guaranteed returns — no such promise may lawfully be made.
• Sign blank documents, blank cheques or blank transfer instructions.
• Share passwords, OTPs or account credentials with any person, including employees of the portfolio manager.
• Pay any upfront fee, which SEBI prohibits.
• Deal with any person claiming to represent the portfolio manager without verifying their identity through the contact details published on this website.

This Investor Charter is published pursuant to the SEBI circular dated 09 December 2021 and is reviewed periodically. Last reviewed: September 2026. In the event of any inconsistency between this Charter and the SEBI (Portfolio Managers) Regulations, 2020 or any circular issued thereunder, the Regulations and circulars shall prevail.