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TRUST INVESTMENT ADVISORS PVT. LTD.

PORTFOLIO MANAGEMENT SERVICES DISCLOSURE DOCUMENT

DATE : 4Th

July 2016

FORM C

SECURITIES AND EXCHANGE BOARD OF INDIA (PORTFOLIO MANAGERS) REGULATIONS, 1993

(Regulation 14)

M/s. Trust Investment Advisors Pvt. Ltd.

Registered Office Address: 109/110, Balarama Premises Co-op. Soc. Ltd.,

Bandra Kurla Complex, Bandra (East), Mumbai – 400 051.

Phone No :- 022 - 40845000

Fax No.022-40845066/022-40845007

Email address: [email protected]

We confirm that:

(i) the Disclosure Document forwarded to the Board is in accordance with the SEBI (Portfolio

Managers) Regulations, 1993 and the guidelines and directives issued by the Board from time to

time;

(ii) the disclosures made in the document are true, fair and adequate to enable the investors to

make a well informed decision regarding entrusting the management of the portfolio to

us/investment in the Portfolio Management;

(iii) the Disclosure Document has been duly certified by an independent Chartered Accountant M/s.

B Y & Associates, Chartered Accountants, 510-513, Apeejay House, 130, Mumbai Samachar

Marg, Mumbai 400 023, Phone No. 022-43215000, firm registration number 123423W on

04.07.2016.

Sd/-

Date: 04.07.2016 ____________________

Ms. Nipa Sheth,

Place: Mumbai Registered Office Address:

109/110, Balarama Premises, Co-op. Soc. Ltd.,

Bandra Kurla Complex, Bandra (East),

Mumbai – 400 051.

Phone No: 022-40845000,

email address: [email protected]

Trust Investment Advisors Pvt. Ltd. Disclosure Document

Page 1 of 34

Portfolio Management Services

Disclosure Document

(As required under regulation 14 of SEBI (Portfolio Managers) Regulations, 1993)

� The Document has been prepared in accordance with the Securities and Exchange Board of India

(Portfolio Managers) Regulations, 1993, as amended from time to time and filed with SEBI.

� The Document has been filed with SEBI along with the certificate in the prescribed format in terms of

regulation 14 of SEBI (Portfolio Managers) Regulation 1993.

� The purpose of the Document is to provide essential information about the portfolio services in a

manner to assist and enable the investors in making informed decision for engaging a Portfolio

Manager.

� The document covers necessary information about the Portfolio Manager required by an investor

before investing, and the investor may also be advised to retain the document for future reference.

� Details of Principal Officer:

Name: Mrs. Nipa Sheth

Registered Office Address: Trust Investment Advisors Pvt Ltd,

109 & 110, First Floor,

Balarama Premises Co-operative Society Ltd,

Village Parigkhari, Bandra Kurla Complex,

Bandra (East), Mumbai – 400051.

Phone No: 022-40845000

Email address: [email protected]

� This Disclosure Document is dated 4th

July, 2016.


Page 2 of 34

Table of Contents

Sr. No. Particulars Page

No.

1. Disclaimer 3

2. Definitions 3

3. Description of the Portfolio Manager 6

4. Penalties, pending litigation or proceedings, finding of inspection or

investigations for which action may have been taken or initiated by any

regulatory authority.

9

5. Details of Services offered 10

6. Risk factors 12

7. Client Representation 16

8. The Financial Performance of the Portfolio Manager 16

9. Portfolio Management Performance of the Portfolio Manager in the last

Three years.

17

10. Fees and Services charged 17

11. Agreement 19

12. Rights and Liabilities of the Client 20

13. Rights, Duties and Liabilities of the Portfolio Manager 21

14. Custody of Securities 23

15. Taxation 24

16. Accounting Policies 26

17. Termination of Agreement 30

18. Disclaimer by Portfolio Manager 30

19. Investors’ Services 31

20. Grievances Redresses / Dispute Handling Mechanism 31

21. Other Disclosures by Portfolio Manager 33

22. List of Approved Share Brokers, involved for Portfolio Management

Activities

33

23. General 34


Page 3 of 34

1. Disclaimer

This Disclosure Document have been prepared in accordance with the SEBI (Portfolio Managers)

Regulations, 1993 as amended from time to time and filed with SEBI. This Document has neither

been approved nor disapproved by SEBI nor has SEBI certified the accuracy or adequacy of the

contents of the Document.

2. Definitions

1. “Act” – means the Securities and Exchange Board of India Act, 1992 (15 of 1992) as

amended from time to time.

2. “Agreement” includes contract entered between the portfolio manager and the client for

the management of funds and / or securities of the client.

3. “Cash Account” means the bank account in which the funds handed over by the client shall

be held by the Portfolio Manager on behalf of the client.

4. “Chartered Accountant” – means a Chartered Accountant as defined in clause (b) of sub-

section (1) of section 2 of the Chartered Accountants Act, 1949 (38 of 1949) and who has

obtained a certificate of practice under sub-section (1) of section 6 of that Act.

5. “Client” means anybody corporate, partnership firm, individual, HUF, association of person,

body of individual, trust, Provident Fund, Gratuity Fund, Pension Fund, Superannuation

Fund, statutory authority, or any other person who enters into agreement with the

Portfolio Manager for the management of his portfolio.

6. “Custodian” means the Depository participant who holds the shares, securities and cash on

behalf of the client.

7. “Discretionary Portfolio Manager” means a portfolio manager who exercises or may, under

a contract relating to Portfolio Management, exercises any degree of discretion as to the

investments or management or administration of the portfolio of securities and / or the

funds of the clients, as the case may be.

8. “Non-Discretionary Portfolio Manager” means a portfolio manager who manages the funds

and/or securities, in accordance with the directions of the clients.

9. “Fund” means the monies placed by the client with the Portfolio Manager and any

accretion thereof.


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10. “Fund Manager” (FM) means the individual/s appointed by the portfolio manager who

manages, advises or directs or undertakes on behalf of the client (whether as a

discretionary Portfolio Manager or otherwise) the management or administration of a

portfolio of securities or the funds of the clients, as the case may be.

11. “NAV” means the net asset value of the Portfolio and shall be aggregate of (a) the amount

of Cash in the cash account: and (b) the value of the Client Securities calculated on the

basis of the closing rates as on the immediately preceding trading day and (c) accrued

interest on the security, (d) mutual fund, (e) Application Money (f) interest on application

money, (g) dividend including dividend on mutual fund minus (h) TDS (if any).

12. “Person directly or indirectly connected,” means any person being an associate, subsidiary,

inter-connected company or a company under the same management within the meaning

of section 370(1B) of the Companies Act, 1956 or in the same group.

13. “Portfolio means the total holdings of securities belonging to the client, the idle cash and

cash equivalents.

14. “Portfolio Manager “ (PM) means Trust Investment Advisors Pvt. Ltd. who has obtained

certificate from SEBI dated 25th

September 2006 to act as a Portfolio Manager under

Securities and Exchange Board of India (Portfolio Managers) Rules and Regulations, 1993,

vide Registration No. INP000001843 and subsequently renewed on 29th

September 2009

for the period from 01st

October 2009 to 30th

September 2012 and subsequently renewed

on 8th

January 2013 for the period from 01st

October 2012 to 30th

September 2015 and

further subsequently renewed on 15th

December 2015 for the period from 01st

October

2015 to 30th

September 2018.

15. “Principal Officer” a director of the Portfolio Manager who is responsible for the activities

of portfolio management and has been designated as principal officer by the Portfolio

Manager.

16. “Regulation” – means the Securities and Exchange Board of India (Portfolio Manager)

Regulations, 1993 as amended by Securities and Exchange Board of India (Portfolio

Managers) Amendment Regulations, 2002 and as may be amended by SEBI from time to

time.


Page 5 of 34

17. “Rules” – means the Securities and Exchange of India (Portfolio Managers) Rules, 1993.

18. “SEBI/Board” means the Securities and Exchange Board of India.

19. “Securities” means and includes “security” as defined under the securities contracts

(regulations) Act, 1956 and also includes Central/State Government Securities, Bonds,

negotiable instruments including usance bills of exchange, trade bills, deposits or other

money market instruments, shares (whether dematerialized or otherwise), scrips, stock,

warrants, debentures, preference shares, ADRs GDRs, foreign currency commitments,

hedged, swaps or netting of any other securities issued by any company or other body

corporate, any trust, any entity, and all money rights or property that may at any time be

offered or accrue (whether by right, bonus, redemption, preference, option or otherwise)

and whether in physical and in dematerialized form in respect of any of the foregoing or

evidencing or representing rights or interest therein; convertible debentures, non-

convertible debentures, fixed return investments, floating rate instruments, equity linked

instruments or other marketable securities of a like nature in or of any incorporated

company or other body corporate, derivative instruments, options, futures, swaps,

commercial paper, certificates of deposits, units issued by Unit Trust of India and/or by any

mutual funds and units issued by any collective investment scheme to the investors in such

schemes, mortgage backed or other asset backed securities issued by any institution or

corporate, security receipts as defined in clause (zg) of section 2 of the Securitization and

Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002,

cumulative convertible preference shares issued by any incorporated company and

securities issued by the Central Government or a State Government, right or interest in

securities or any other securities that may be issued from time to time by the concerned

authorities, any other instrument or investments as may be permitted by applicable law

from time to time.

20. “Securities Lending Scheme” means the securities lending as per the Securities Lending

Scheme, 1997 specified by the Board.

21. “Product” means any of the current investment products or such product that may be

introduced at any time in future by the portfolio manager.


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Words and expressions used in this disclosure document and not expressly defined shall be

interpreted according to their general meaning and usage. The definitions are not exhaustive.

They have been included only for purpose of clarity and shall in addition be interpreted according

to their general meaning and usage and shall also carry meanings assigned to them in regulations

governing Portfolio Management Services.

3. Description of the Portfolio Manager

Trust Group is one of the leading players in the origination, intermediation, distribution and fund

management in the Indian Fixed Income and Money Market through our following Group

Companies.

Trust Capital Services (India) Pvt. Ltd (TCS):

TCS, incorporated in 2001, is the flagship company of the group which provides intermediation

and distribution services to banks, development finance institutions, primary dealers, insurance

companies, mutual funds, provident fund trust among others. The company is Deposit Based

Member of BSE and having SEBI registration number INZ000033332 vide dated 28.03.2016.

Trust Financial Consultancy Services Pvt. Ltd (TFCS):

Trust Financial Consultancy is member of NSE Cash & Derivative & Debt Segment having SEBI

Registration No. INB231198731, INF231198731 & INF231198731 respectively. TFCS is also having

membership of Capital Market and Derivative Market of BSE having SEBI Registration No.

INB011198737 & INF011198737 respectively. It is also member of Metropolitan Stock Exchange

of India Ltd. in Currency Derivative Segment, Capital Market and Derivatives / Debt segment

having registration No. INE261198731, INB261198734 and INF261198734 respectively. Further, it

has also obtained Registration with SEBI as Research Analyst having registration no.

INH000001543 w.e.f. 25th

August, 2015 .

Previously, TFCS, an inter -dealer broker, was member of the Wholesale Debt market Segment of

the National Stock Exchange of India (NSE) since 2003, and has since been providing

intermediation services in Government Securities, Treasury Bills, Public Sector Undertaking

Bonds, Corporate Bonds, State Development Loans, Tax Free Bonds among others.


Page 7 of 34

Trust Investment Advisors Pvt. Ltd (TIA):

TIA is a subsidiary of TCS and was incorporated in 2006. TIA is a Securities and Exchange Board of

India registered as Category 1 Merchant Banker having SEBI Registration No.INM000011120 is

permanent certificate dated 14th

March, 2013 and Portfolio Manager having SEBI Registration

No.INP000001843.

Trust Investment Advisors Pvt. Ltd. is a private limited company incorporated under the

provisions of the Companies Act, 1956 having registered office at 109 & 110, First Floor,

Balarama Premises Co-operative Society Ltd, Village Parigkhari, Bandra Kurla Complex, Bandra

(East), Mumbai – 400051.

Trust Investment Advisors Pvt. Ltd. has obtained Portfolio Manager Certificate of Registration

No.INP000001843 from SEBI effective from 01.10.2006 to 30.09.2009 and was renewed on 29th

September, 2009 for the period from 01.10.2009 to 30.09.2012 and was subsequently renewed

on 8th

January 2013 for the period from 01.10.2012 to 30.09.2015 and was subsequently further

renewed on 15th

December 2015 for the period from 01.10.2015 to 30.09.2018.

The paid up capital of Trust Investment Advisors Pvt. Ltd. is Rs. 6.50 Crores, Trust Capital

Services (I) Pvt. Ltd, holds 99.85% of the equity capital of the Portfolio Manager.

Trust-Plutus Wealth Managers (India) Pvt. Ltd.:

Incorporated in 2010, Trust-Plutus Wealth Managers (India) Pvt. Ltd. is in the business of

providing Wealth Advisory Services and distribution of Mutual Funds, Insurance, and Securities

etc.

TrustPlutus Family Office & Investment Advisers (India) Private Limited:

TrustPlutus Family Office & Investment Advisers (India) Private Limited obtained the license of

Investment Advisors in 2013. TrustPlutus Family Office and Investment Advisers (India) Pvt. Ltd. is

subsidiary of TrustPlutus Wealth Manager (India) Pvt. Ltd. TrustPlutus is a unique client–centric

advisory platform offering bespoke wealth solutions. It focus on 5 key client segments; viz Small

and Medium enterprises, Family Legacies, Top Management, Professionals and Non Residents. It

is committed to providing goal based solutions through a scientific and disciplined process, aimed

at mitigating risks. Its deep commitment to its clients’ needs and aspirations together with the


Page 8 of 34

analytical vigour, strong governance, wisdom and insight of its team enables it to create superior

risk adjusted solutions.

TrustPlutus Family Office & Investment Advisers (India) Private Limited has been incorporated to

comply with SEBI (Investment Advisers) Regulations, 2013 vide registration certificate no.

INA000000557 dated 18th December 2013 and is valid up to 17th

December, 2018.

Promoters of the Portfolio Manager and their background

Trust Capital Services (I) P. Ltd., holding company was incorporated on 2nd

February 2001 and is

actively operating since then. Last year the company had applied for Deposit Based Membership

of BSE and had received the SEBI registration certification having registration number

INZ000033332 vide dated 28.03.2016. The company has a vast experience in Indian Debt Market

and equity market with offices in 9 cities viz., Mumbai, New Delhi, Kolkata, Chennai, Hyderabad,

Bengaluru, Pune, Bharuch, and Ahmedabad.

Board of Directors and their background:

Director Mrs. Nipa Sheth & Mrs. Nisha Mehta both are having vast experience in Debt & Equity

market.

Mrs. Nipa Sheth, Director

Director Mrs. Nipa Sheth is a qualified Chartered Accountant (4th

Rank Holder) and Chartered

Financial Analyst and she is having vast experience of approx. Nineteen years in Debt Market and

fifteen years in Equity Market.

Mrs. Nisha Mehta, Director

Director Mrs. Nisha Mehta is a qualified Architect and she is having experience of approx. Fifteen

years in Debt Market and Approx. Nineteen years in architecture.

The Company along with its Associates is catering to various clients on PAN India basis.

The Company along with its Associates has gained expertise in Government Securities, Corporate

/ PSU Bonds, State Government Bonds and RBI Relief Tax Free Bonds; and also created a strong

brand loyalty of customers which comprises of Financial Institutions, Banks, Provident Funds,

Mutual Funds, Primary Dealers, Charitable Organisation and High Net worth Individuals.


Page 9 of 34

Top 10 Group Companies under the same Management as per section 370(1B) of the Companies

Act, 1956, of the Portfolio Manager in India.

1) Trust Capital Services (India) Private Limited.

2) Trust Financial Consultancy Services Private Limited.

3) Trust-Plutus Wealth Managers (India) Pvt. Ltd.

4) Chanakya Corporate Services Pvt. Ltd.

5) Sankhya Financial Services Pvt. Ltd.

6) Calculas Financial Consultants Pvt. Ltd.

7) Abhigam Shares and Securities Pvt. Ltd.

8) Trust Capital Holdings Pvt. Ltd.

9) Chanakya Wealth Creation Pvt. Ltd.

10) TrustPlutus Family Office & Investment Advisers (India) Private Limited

4. Penalties, pending litigation or proceedings, findings of inspection or investigations for which

action may have been taken or initiated by any regulatory authority

SR.

NO.

PARTICULARS REMARKS

1 All cases of penalties imposed by the Board or the directions

issued by the Board under the Act or Rules or Regulations made

there under:

None

2 The nature of the penalty / direction:

None

3 Any pending material litigation / legal proceedings against the

portfolio manager / key personnel with separate disclosure

regarding pending criminal cases, if any:

None

4 Any deficiency in the systems and operations of the portfolio

manager observed by the Board or any regulatory agency:

None


Page 10 of 34

5 Any enquiry / adjudication proceedings initiated by the Board

against the portfolio manager or its directors, principal officer or

employee or any person directly or indirectly connected with

the portfolio manager or its directors, principal officer or

employee under the Act or Rules or Regulations made there

under:

None

6 Penalties imposed for any economic offence and/or violation of

any securities laws

None

5. Details of Services Offered

a) Services offered

(i) Discretionary Portfolio Management -

The portfolio account of the client is managed at the full discretion and liberty of the

Portfolio Manager. Thus the choice and timing of investment rests solely with the

Portfolio Manager. The portfolio managers’ decision (taken in good faith) in

deployment of the Clients’ account is absolute and final and cannot be called in

question or be open to review at any time during the tenure of the agreement or

any time thereafter except on the ground of malafide, fraud, conflict of interest or

gross negligence. The equity related portfolios (if any) shall be managed under the

Chanakya Wealth Creation name.

(ii) Non-discretionary Portfolio Management -

The portfolio account of the client is managed in accordance with the directions of

the client.

(iii) Advisory Services –

The Portfolio client is given purely advisory services as stipulated under SEBI PMS

Regulations and in accordance with the requirement of the client. Portfolio Manager

gives advice to the client regarding investment/disinvestment in Securities.

However, discretion lies with the client whether to act upon it or to ignore the

advice. The Portfolio Manager will provide advisory portfolio management services,

in terms of the SEBI (Portfolio Manager) Regulations, 1993 and SEBI (Investment


Page 11 of 34

Advisers) Regulations, 2013, which shall be in the nature of Investment advice and

may include advice relating to investing in, purchasing, selling or otherwise dealing

in securities or investment products, and advice on investment portfolio containing

securities or investment products, whether written, oral or through any other

means of communication for the benefit of the client. Investment advice shall be for

an agreed fee structure and for a period agreed and entirely at the client’s risk. The

Portfolio Manager shall act in a fiduciary capacity towards its client.

b) Investment objective –

The general objective is to formulate and device the investment philosophy to achieve

long term growth of capital by investing in assets, which generate reasonable return and

to ensure liquidity. The actual portfolio management style will vary in line with each

client profile with regard to his risk tolerance levels and specific preferences or concerns.

Objective of the Derivative Exposure: The objective to use derivatives is purely to protect

the portfolio in case of a severe market correction. We seek to use derivatives purely to

protect client’s portfolio in case of sharp drawdowns of the aggregate market. The

Derivatives will only be used for hedging and/or portfolio rebalancing.

c) Types of Securities –

The portfolio manager/fund manager shall invest in all such types of securities as defined

herein above (Please refer to definitions) and in all such securities as permissible from

time to time.

Type of Derivatives to be used –

Only options on the Nifty / Sensex will be used for the purpose (i.e. broad based market

indices) of hedging and portfolio rebalancing. The position will always be as buyer/holder

of the option.

Exposure: The maximum exposure in derivatives will not exceed the limit specified in the

agreement in absolute term and in percentage terms.

d) The policies for investments in associates/ group companies:

TIAPL currently does not intend to invest in any of its associate or group companies.


Page 12 of 34

e) Minimum Investment Amount-

The Portfolio Manager will not accept a corpus of less than Rs. 25.00 lacs or such

minimum amount as specified by SEBI from time to time. The client may on one or more

instances or on a continual basis, make further placements of funds/ securities under the

services.

6. Risk Factors

1. Securities investments are subject to market risk and there is no assurance or guarantee

that the objectives of the investment will be achieved.

2. The past performance of the portfolio manager does not indicate the future

performance.

3. The Portfolio Manager is neither responsible nor liable for any losses resulting from the

operations in good faith of the Portfolio Products.

4. The investments made by the Portfolio Manager are subject to risks arising from the

investment objective, investment strategy and asset allocation.

5. The investment made by the Portfolio Manager is subject to risk arising out of non –

diversification, etc.

6. The investments in equity related instruments of mutual funds are subject to interest

rate risks, credit risks, political and geopolitical risks, currency risks, country risks and

risks arising from changing business dynamics. This may adversely affect returns.

7. At times the performance of the Portfolio would depend on the performance of such

companies / industries / sectors of the economy / class of assets. Technology,

pharmaceutical stocks and some of the investments in niche sectors run the risk of high

volatility, high valuation, obsolescence and low liquidity.

8. The Portfolio Manager may invest in non-publicly offered debt securities and or unlisted

equities. This may expose the portfolio to liquidity risks.


Page 13 of 34

9. The value of the Portfolio may increase or decrease depending upon various market

forces affecting capital market, money market, debt market in general or in particular.

10. Reinvestment Risk: Since interest rates are vary from time to time, interim cash flows

from interest-bearing debt instruments may be reinvested at a lower yield than the

original yield.

11. The liquidity of the investments is guided and inherently restricted by trading volumes in

the securities in which the Portfolio Manager may invest. This may limit the Portfolio

Manager's ability to freely deal with securities in the Portfolio.

12. The Portfolio Manager may, considering the overall level of risk of the portfolio, invest in

lower rated/unrated securities that offer higher yield, which may increase the risk to the

portfolio. Such investments shall be subject to the scope of investments laid down in the

executed Agreement.

13. Trading volumes, settlement periods and transfer procedures may restrict the liquidity of

the investments made by the Portfolio Manager. Different segments of the Indian

financial markets have different settlement periods and such periods may be extended

significantly due to unforeseen circumstances. The inability of the Portfolio Manager to

make intended security purchases due to settlement problems could result in missing out

certain investment opportunities. By the same rationale, the inability to sell securities

held in Portfolio due to the absence of a well developed and liquid secondary market for

debt securities would result, at times, in potential losses in the Portfolio.

14. Securities which are not quoted on the market are inherently illiquid in nature and carry

a larger liquidity risk in comparison to the securities that are listed on the exchanges or

offer other exit options to the investor, including a put option. The Portfolio Manager

may choose to invest in unlisted securities that offer attractive yields. This may however

increase the risk of the Portfolio.


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15. Risks in Derivatives: An option holder runs the risk of losing the entire amount paid for

the option in a relatively short period of time. This risk reflects the nature of an option as

a wasting asset which becomes worthless when it expires. An option holder who neither

sells his option in the secondary market nor exercises it prior to its expiration will

necessarily lose his entire investment in the option if the price of the underlying asset

does not change in the anticipated direction before the option expires to an extent

sufficient to cover the cost of the option (the premium), the investor may lose all or a

significant part of his investment in the option.

16. While securities that are listed on the stock exchange carry lower liquidity risk, the ability

to sell these investments is limited by the overall trading volume on the stock exchanges.

Money market / debt securities while fairly liquid, lack a well-developed secondary

market, which may restrict the selling ability of the Portfolio Manager and may lead to

investments incurring losses till the security is finally sold.

17. In any Scheme which may invest predominantly in schemes of Mutual Funds - Debt

and/or equity and other instruments, its performance may depend on that of the

underlying schemes of Mutual Funds. Any change in investment policies or fundamental

attributes of underlying schemes could adversely affect performance of the portfolio.

Also, for a sharp increase in the stock market during the period of investment, the return

of the portfolio might be less than that given by direct investment of similar amounts in

equities.

18. The Clients may not be able to avail of securities transaction tax credit benefit and/or tax

deduction at source (TDS) credit and this may result in an increased incidence of tax on

the Clients. The Client may incur a higher rate of TDS/ Dividend Distribution Tax in case

the investments are aggregated in the name of the Portfolio Management plan.

19. The investments of the fund and resultant investment are subject to a very wide range of

risks which include amongst others inter alia:

a) Overall economic slowdown, unanticipated bad corporate performance,

environmental or political (including changes in tax laws and rates), changes in


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government policies and regulations with regards to industry and exports,

technological change, obsolescence of market technology, changes of

local/international markets which affects stock market.

b) Act of state, sovereign action, Acts of God, natural calamities, Acts of war, civil

disturbance.

c) Delisting or market closure, relatively small number of scrips accounting for a large

proportion of trading volume.

d) Misjudgment of Portfolio Manager, unsystematic settlement procedures, refusal or

delay in registration of securities, non-receipt of interest or dividend etc.

20. Limited liquidity in the market, settlement risk, impeding readjustment of portfolio

composition, highly volatile money markets in India. There is also risk of total loss of

value of an Asset, possibilities of recovery of loss in investments only through expensive

legal process. Such loss could arise due to factors which by way of illustration, include,

default or non – performance of a third party, company’s refusal to register a security

due to legal stay or otherwise, disputes raised by third parties. Misjudgment by the

portfolio manager or his incapacitation due to any reason however remote is also a risk.

Thus the investment in Indian Money Market involves above average risk for investors

compared with other types of investment opportunities. Investments will be of a longer

duration compared to trading in securities. There is a possibility of the value of

investment and the income there from falling as well as rising depending upon the

market situation.

21. Performance of the Portfolios may be impacted as a result of specific investment

restrictions provided by the client.

22. The Portfolio Manager is not guaranteeing or assuring any return on investment.


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7. Client Representation

i. The Portfolio Management services performance for the previous three years ended on, 31st

March 2016, 31st

March 2015 & 31st

March 2014 & are as follows.

Note: Data mentioned above are status as on the last day for the financial year ended i.e.

31.03.2016, 31.03.2015 & 31.03.2014 respectively.

ii. Complete disclosure in respect of transactions with related parties as per the standards

specified by the Institute of Chartered Accountants of India.

Related parties with whom transactions have taken place during the year

(F .Y. 2015-2016 as per Provisional Unaudited Books) are: (Refer – Annexure 1)

8. The Financial Performance of the Portfolio Manager

The financial performance of the company for the year, 2015-2016 (unaudited), 2014-15

(audited), 2013 – 14 (audited) and 2012-13 (audited) are as follows.

Year Turnover(Rs. in Lacs) Profit / (Loss)

(Rs. in Lacs)

2015-2016 (Unaudited) 10,090.10 2,145.91

2014-2015 (Audited) 8,459.94 3,612.17

2013-2014 (Audited) 4,240.91 876.47

2012-2013 (Audited) 6,627.59 3,368.81

Category of

Clients

Discretionary

/ Non-

Discretionary

/ Advisory

31-03-2016 31-03-2015 31-03-2014

No. of

Clients

Funds

Managed

(Rs. In Cr)

No. of

Clients

Funds

Managed

(Rs. In Cr)

No. of

Clients

Funds

Managed

(Rs. In Cr)

Associate /

Group

Companies

Discretionary

4

14.66

1

14.46

1

9.37

Other

Clients

Discretionary

164

645.79

137

524.08

96

254.30

Advisory

8

6,579.11

7

1,228.61

5

799.40

Grand Total

176

7,239.56

145

1,767.15

102

1,063.07


Page 17 of 34

9. Portfolio Management performance of the portfolio manager in the last three years.

The performance of portfolio for the F. Y. 2015-16, F. Y. 2014-15 and F. Y. 2013-14 are as follows.

Portfolio Management performance

Year

(2015-2016)

Year

(2014-2015)

Year

(2013-2014)

Segment - DEBT PMS

Portfolio Performance

(%), Net of all fees and

charges levied by the

portfolio manager.

Individual Clients 8.45% 14.43% 8.88%

Corporate Clients 8.61% 13.59% 9.26%

Benchmark

Performance %

CRISIL Fund ~Dx* NIL NIL NIL

CRISIL CompBex **

8.24% 14.35% 4.33%

Segment - EQUITY PMS

Portfolio Performance

(%), Net of all fees and

charges levied by the

portfolio manager.

Individual Clients (0.42)% 41.56% 40.58%

Corporate Clients (2.36)% 45.33% 28.85%

Benchmark

Performance %

S&P CNX NIFTY% (8.86)% 26.65% 17.98%

** CRISILFUND ~ DX is an index of all debt schemes of mutual funds and CRISIL CompBex is a

Composite Bond Index. Both are performance indexes that we use as performance benchmark

indices

* CRISIL Fund ~Dx is not provided since CRISIL has discontinued using and providing CRISIL Fund

~Dx as index from Financial Year Ended on 31.03.2014.

10. Fees and Services Charged (To be based on actuals)

1. Investment management fee: i.e. Fixed Fees charged as agreed with the client wide

terms and conditions mentioned in the agreement relating to the Portfolio Management

Services offered to the Clients.

2. Performance management fee i.e. a performance fee based on profit slabs provided in

the portfolio agreement is charged as agreed with the client vide terms and conditions

mentioned in the agreement.


Page 18 of 34

3. The fees charged to the client for PMS Service comes under “Fees for technical services”

under Sec 194J of the Income Tax Act 1961. This section calls for withholding tax on the

fees that the client pays to the portfolio manager if he or she falls under

a. An Individual / HUF whose total sales / gross receipt or turnover from business

or profession carried on by him exceed the monetary limit specified under

clause (a) or clause (b) of Sec. 44AB during the previous year immediately

proceeding the financial year.

b. Corporates.

Custodian fee / Depository Charges: Charges relating to custody and transfer of shares,

bonds and units, opening and operation of demat account, dematerialisation and

rematerialisation, and / or any other charges in respect of the investment etc. The actual

fees levied by the custodian shall be charged to the client as mentioned in the agreement

with the client and as agreed between the Portfolio Manager and the Custodian from

time to time.

4. Registration and transfer agents' fees :

Fees payable for the Registrars and Transfer Agents in connection with effecting transfer

of any or all of the securities and bonds including stamp duty, cost of affidavits, notary

charges, postage stamps and courier charges.

5. Brokerage, transaction costs and other services: The brokerage and other charges like

stamp duty, transaction cost and statutory levies such as service tax, securities

transaction tax, turnover fees and such other levies as may be imposed upon from time

to time.

6. Fees and charges in respect of investment in mutual funds: Mutual Funds shall be

recovering expenses or management fees and other incidental expenses and such fees

and charges shall be paid to the Asset Management Company of the Mutual Funds on

behalf of the Client. Such fees and charges are in addition to the portfolio Management

fees described above.

7. Certification charges or professional charges:

The charges payable to professional services like accounting, taxation, certification and

any other legal services, etc.


Page 19 of 34

8. Securities lending and borrowing charges: The charges pertaining to the lending of

securities, costs of borrowings and costs associated with transfer of securities connected

with the lending and borrowing transfer operations.

9. Any incidental and ancillary out of pocket expenses:

All incidental and ancillary expenses not recovered above but incurred by the Portfolio

Manager on behalf of the client shall be charged to the Client.

The Portfolio Manager shall deduct directly from the cash account of the client all the

fees/costs as specified above and shall send a statement to the client for the same.

10. The portfolio manager shall deduct directly from the cash account of the client all the

fees/costs specified above. Other expenses, which could be attributable to the Portfolio

Management, would also be directly deducted and the client would be sent a statement

about the same.

11. The fee so charged may be a fixed fee or a return based fee or a combination of both as

agreed in the agreement.

11. Agreement

1. The Portfolio Manager before taking up an assignment of management of funds or

portfolio of securities on behalf of the client, enters into an agreement in writing with

such client clearly defining the inter se relationship and setting out their mutual rights

liabilities and obligations relating to the management of funds or portfolio of securities,

containing such details as per the regulations.

2. The money or securities accepted by the portfolio Manager shall not be invested or

managed by the Portfolio Manager except as mentioned in terms of the agreement

between the Portfolio Manager and the client.

3. The Portfolio Manager shall not change any terms of the agreement without prior

written consent of the client

4. Generally, The term of the PMS Agreement shall initially be for a period of one year from

the Activation Date (“Term”) and, unless terminated by either Party in accordance with

the terms of the PMS Agreement, shall be deemed to be automatically renewed from the

next day of date of expiry of the Term on the such terms and conditions as may be


Page 20 of 34

mutually agreed upon by the Parties in writing, till any further communication by either

of the party to terminate the same. The Client shall be entitled to terminate the PMS

Agreement before the expiry of the term according with the terms / clauses specified in

the said agreement.

12. Rights and Liabilities of the Client

1. Rights:

a. The client has a right to obtain a copy of the Disclosure Document at least 2 days

prior to signing the agreement.

b. Client shall obtain reports for a period not exceeding six months containing

details as specified in regulation 21(1) and as agreed in the agreement with the

portfolio manager except for the auditor’s report which shall be submitted

annually.

c. The portfolio manager shall provide to the client with a transaction statement

once in a quarter or as stated in the agreement with the client.

d. The client will be provided a statement reflecting portfolio status and a

statement of profit and loss on a quarterly basis.

2. Liabilities & Duties

a. The liability of the client shall be to the extent of his investments.

b. The client shall maintain utmost secrecy with regard to investment made by the

Portfolio Manager on its behalf. In no case shall the Client replicate for its or for

the benefits of others, the investments made by the Portfolio Manager.

c. The client shall disclose to the Portfolio Manager from time to time whether it is

privy to price sensitive information, such that a conflict of interest may arise

where the Portfolio Manager to buy Securities on behalf of the Client.

d. The Client shall pay the agreed fees at the agreed times to the Portfolio Manager

in the manner as provided in the agreement.

e. The Client shall not directly dispose of or acquire any Securities held in the

portfolio, except as agreed by the Portfolio Manager. The Custodian appointed

under the Custodian Agreement shall not be authorized to accept the


Page 21 of 34

instructions directly from the client. The Client shall not issue any direct

instructions to the Custodian or the broker in this respect. In case the client

issues any instructions directly to the Custodian or the broker, the Portfolio

manager shall not be responsible for any loss or claim or damage arising there

from. In any such case, in respect of any sale, the sale proceeds shall be made

over by the Client to the Portfolio Manager as part of the investible funds and in

case of any purchase, the client shall make payment directly to the Seller.

f. The Client shall within seven days notify the Portfolio Manager if it notices any

discrepancies or shortfalls in the Custodian holding statement. In case the Client

does not notify the Portfolio Manager of any discrepancies or shortfalls in the

Custodian holding statement the same shall be deemed to be correct.

g. The Client shall plan and pay any tax (long term or short term capital gains,

income tax etc.) And other governmental liabilities that may arise as a

consequence of the portfolio transactions on its account. The Portfolio manager

shall during its meeting with the Client be available to help the Client plan its tax

outflows. However, it should be clearly understood that tax considerations

should not be allowed to supersede investment decisions even though the

Portfolio Manager recognizes the desirability post tax returns.

h. The Client shall render all possible assistance, and provide requisite information

for the purpose of assisting the Portfolio Manager in determining, evaluating and

investing the available funds of the Client. The Client shall also immediately

provide to the Portfolio Manager any information in respect to the investments

or possible investments as may be available with it.

i. The Client agrees that the investments made by the Portfolio Manager shall be at

the sole discretion, judgment and opinion of the Portfolio Manager in case of

discretionary portfolio management service.

13. Rights, Duties and Liabilities of the Portfolio Manager

1. The Portfolio Manager shall act in fiduciary capacity with regard to the Client’s funds. It

shall not derive any benefit from the Client’s funds or Securities purchased for the Client

and shall strive to safeguard the Client’s interests to the best of its ability at all times.


Page 22 of 34

2. Securities shall be held directly in the name of the client/portfolio manager and shall be

physically kept with the Custodian who shall be appointed by the Portfolio Manager. The

Custodian shall follow up all entitlements such as bonus, interest, and principle

redemption, right, dividend, etc on behalf of the client. The custodian shall provide a

Statement of Portfolio Holdings to the Portfolio Manager who shall forward it to the

Client at regular intervals as agreed. The Client’s Securities shall always belong to the

Client and the Portfolio Manager shall not pledge them or any of them with any entity, or

derive any benefit from the same, without specific written consent of the client.

3. The Portfolio Manager shall provide the Client with a formal Portfolio Valuation

Statement. The Portfolio Manager shall make itself available for consultation with the

Client at least once every six months.

4. The Portfolio Manager shall ensure proper and timely handling of complaints from the

Clients and take appropriate action immediately.

5. The Portfolio Manager will make best efforts to safeguard the Client’s interests with

regard to dealings with capital market intermediaries such as brokers, custodians,

bankers etc. Any contract or understanding arrived at by the Portfolio Manager with any

such intermediary shall be strictly on behalf of the Client, and the Portfolio Manager shall

not be responsible for the due performance of the contract or understanding by the

intermediary.

6. The Portfolio Manager shall on a best effort basis, assist the Custodian in attending to the

complaints of the Client in respect of the non-receipt of dividends, bonus shares,

interest, receipt of entitlements and subscription of right shares, transfer of shares and

the like. However, the responsibility and liability in respect of the aforesaid shall be

entirely that of the Custodian.

7. The Portfolio Manager:

a. Shall not trade on margin or on a speculative basis on behalf of the Client. All

transaction shall be on delivery basis.

b. Shall not pledge or give on loan securities held on behalf of Client to a third person

without obtaining a written permission from the Client.


Page 23 of 34

c. The portfolio manager can also invest funds of his clients in derivatives or as

specified in the contract but will not leverage portfolio in respect of investment in

derivatives.

8. The Portfolio Manager shall furnish the following reports periodically to the Client (not

exceeding a period of three months and as and when required by the client). Such report

shall contain the following details namely.

a. Report on the composition and value of the portfolio, description of securities,

number of securities, value of each security held in the portfolio, cash balance,

aggregate value of the Portfolio, interest accrued etc as on the date of the report.

b. Report on transactions undertaken during the period of report including date of

transaction and details of purchases and sales.

c. Report on beneficial interest received during that period in respect of interest,

dividend, bonus shares, rights shares and debentures.

d. Report on expenses incurred in managing the portfolio.

e. Details of risk foreseen by the Portfolio Manager and the risk relating to the

Securities recommended by the Portfolio Manager for investment.

9. The Portfolio Manager shall, ordinarily purchase or sell securities separately for each

Client. However, in the event of aggregation of purchases or sales for economy of scale,

allocation shall be done on a pro-rata basis at the weighted average price of the day’s

transactions. The Portfolio Manager shall not keep any open position in respect of

allocation of sales or purchases affected in a day.

14. Custody of Securities

Custody of all securities of the client shall be with the custodian who shall be appointed by the

Portfolio Manager.

The custodian shall act on instruction of the Portfolio Manager.

All such custodian fees, charged by the custodian shall be payable by the client.


Page 24 of 34

The Portfolio Manager shall not be liable for any act of the custodian done with or without the

instruction of the Portfolio Manager, which may cause or is likely to cause any loss or damage to

the client.

15. Taxation

Income on Investment in Securities is subject to tax in the following manner:

a) Dividend

Dividends declared, distributed or paid on or after April 1, 2003 by domestic companies

will be exempt in the hands of the shareholder recipient but tax on distributed profits at

applicable rates will be payable by the domestic company. However, from 1st

April 2016,

Individuals, Firms and HUF Resident in India receiving dividend income in excess of Rs. 10

lakhs shall be chargeable to additional Tax @ 10% plus applicable surcharge and cess (as

may be applicable) on gross basis under section 115BBDA.

b) Interests on Investment are taxable except in certain cases where it is exempted from tax

under Income Tax Act 1961.

c) In case the securities are sold within one year (for listed securities except for units other

than units of equity oriented mutual funds) or within three years (for unlisted securities)

from the date of purchase, the resultant gains or losses are termed as short term capital

gains or losses. Short term gains arising out of transfer of equity shares if the securities

are sold on a recognized stock exchange in India and on which securities transaction tax

has been paid are taxed at a concessional rate of 15% (as increased by surcharge plus

education cess), in other cases they would be taxed at the slab rate applicable to the

respective PMS client type.

In case the securities are sold after one year (for listed securities ) or three years (for

unlisted securities) and three years for units other than units of equity oriented mutual

funds from the date of purchase, the resultant gains or losses are termed as long term

capital gains or losses and are exempt from income tax if the gain is arising out of

transfer of equity shares which are sold on a recognized stock exchange in India and on

which securities transaction tax has been paid; failing which they would be taxed at 10%

(as increased by surcharge plus education cess) in case of listed securities (where STT is

not paid) and 20% (as increased by surcharge plus education cess) in case of unlisted

securities and units other than units of equity oriented mutual funds.


Page 25 of 34

Note: “Listed Securities” as defined under the explanation to section 112(1) of Income Tax Act,

means the securities as defined in clause 2(h) of Securities Contract (Regulations) Act, 1956 and

listed on any recognized stock exchange in India.

“Unlisted Securities” means securities other than listed securities.

“Units” shall have the meaning assigned to it in clause (b) of explanation to section 115AB of

Income Tax Act, 1961.

The following are the tax provisions presently applicable to clients investing in the Portfolio

Management Products under the Income Tax Act, 1961.

Tax on Long Term Capital Gain:

If the capital asset, which is transferred, is equity share or units of equity oriented mutual funds

and transaction is subject to Securities Transaction Tax, the Long Term Capital Gain is not

chargeable to tax. In other cases, tax will be calculated as follows

Capital Asset If it is not subject to Securities Transaction Tax

Long Term Short Term

Without

Indexation

With Indexation

1.Debenture Listed 10 % Not Applicable Normal

2.Debenture Non Listed 20 % Not Applicable Normal

3.Government Securities 10 % 20 % Normal

4. Bonds Listed 10% Not Applicable Normal

5. Bonds Non Listed 20% Not Applicable Normal

TDS

If any tax is required to be withheld on account of any future legislation, the portfolio manager

shall be obliged to act in accordance with the regulatory requirements in this regard. Interest

would be subject to tax as per prevailing provisions of the Income Tax Act, 1961.

Advance Tax Obligations

It shall be the client’s responsibility to meet the advance tax obligations payable on the due dates

as per the Income Tax Act, 1961.


Page 26 of 34

Provisions of Income Tax Act 1961, undergoes change frequently and is also based on the status

of the client, thus the client is advised to consult his/her tax consultant for appropriate advice on

tax treatment of income indicated herein.

The fees charged to the client for PMS come under the ambit of “fees for technical services”

under Section 194J of the Income Tax Act, 1961(“the Act”). As the section calls for withholding

tax, the client is required to withhold tax @ 10 % excluding service tax, on the fees that the client

pays to the Portfolio Manager, if he / she fall under the following two categories:

a) An Individual / HUF whose total sales / gross receipt or turnover from business or profession

carried on by him exceed the monetary limit specified under clause (a) or clause (b) of Sec. 44AB

during the previous year immediately preceding the financial year

b) Corporates

This implies, the Client (as mentioned in point ‘a’ and ‘b’ above) while making payment of the

fees would deduct tax at Source. The taxes payable on any transactions entered into or

undertaken by the Portfolio Manager on behalf of the client, whether by way of deduction

withholding, payment or other, shall be fully borne by the client. Payment of the tax shall be the

personal responsibility and liability of the client. In case the client deducts and pay the

withholding tax, the client shall provide Tax Deduction Certificate in Form No. 16A as prescribed

under the Income Tax Rules, 1962 to the Portfolio Manager within 30 days from the date of filing

return or due date of filing TDS Return for the quarter whichever is earlier. The Portfolio Manager

is not by law, contract or otherwise required to discharge any obligation on behalf of the client to

pay any taxes payable by the clients.

16. Accounting Policies-

1. Basis of accounting

Books and Records would be separately maintained in the name of the client to account for

the assets and any additions, income, receipts and disbursements in connection therewith, as

provided by the SEBI (Portfolio Management) Regulations, 1993, as amended from time to

time. Accounting under the respective portfolios will be done in accordance with Generally

Accepted Accounting Principles. As SEBI (Portfolio Management) Regulations, 1993, do not

explicitly lay down detailed accounting policies regarding valuation and accounting, such

policies which are laid down under SEBI (Mutual Fund) Regulations would be followed, in so

for as accounting and valuation for equities or equity related instruments are concerned.


Page 27 of 34

a. Equity securities awaiting listing are valued at fair value as determined in good faith by

Trust Investment Advisors Private Limited. Fixed Income Instruments that are awaiting

listing will be valued at cost plus interest accrual till the beginning of the day plus the

difference between the redemption value and the cost spread uniformly over the

remaining maturity period of the instrument.

b. Instruments bought on ‘repo’ basis are valued at the resale price after deduction of

applicable interest up to the date of resale.

c. Investments in Mutual funds will be valued at the repurchase NAV declared for the

relevant schemes on the date of the report or the most recent NAV will be reckoned.

d. In the Derivatives segment, the unrealized gains/losses for Futures and Options will be

calculated by marking all the open positions to market.

e. All Investments will be marked to market.

f. Valuation of Derivatives: Valuation of derivatives will be based on mark to market

valuation methodology based on quotes from National Stock Exchange.

2. Income/expenses

All investment income and Expenses will be accounted on accrual basis. Dividend will be

accrued on the Ex-date of the securities and the same will be reflected in the clients’ books

on the ex-date. Similarly, bonus shares will be accrued on the ex-date of the securities and

the same will be reflected in the clients’ books on ex-date. In case of Fixed Income

instruments, purchased/ sold at Cum-interest rates, the interest component upto the date of

purchase /sale will be taken to interest receivable/payable account and net of interest will be

the cost/sale for the purpose of calculating realized gains/losses.

3. Following are the key accounting policies.

a. Transactions for purchase or sale of investments would be recognized.

(i) Relating to debt instruments would be recognized as of the settlement date and

(ii) Relating to equity instruments as of the trade date and not as of the settlement

date so that the effect of all investments traded during the year are recorded and

reflected in the individual client account for that year.


Page 28 of 34

b. The costs of investments acquired or purchased would include brokerage, transaction

charges, accrued interest, stamp charges and any charge customarily included in the

broker’s contract note trade confirmation or levied by any stature.

1. Debt

Valuation of Debt & Debt Related Instruments:

The valuation will be based on instrument qualifying as TRADED and NON-TRADED

(as per the valuation norms provided by investment committee). The criteria for

deciding the Traded Instrument will be the combination of No. of consecutive trade

days on Exchange, no. of trades, Amount of Traded Value (FV) of the instrument and

other relevant factors.

For Traded Debt Instruments:

All traded security will be valued on weighted average trade price/yield of qualifying

trade days (as per the valuation norms sanctioned by investment committee from

time to time).

For Non-Traded Debt Instruments:

The Instruments that do not fulfill criteria for TRADED SECURITY will be considered

NON-TRADED. Debt Markets in India are shallow and sufficient data points across

the yield curve and rating/maturity/asset classes are not available every day. Apart

from traded prices on the exchanges, FIMMDA reported trades and valuation tools

(viz. CRISIL Bond Valuer) are also considered and form an input in finalising the base

curves and spreads over the base curves. Hence the end of the day valuation yields

are result of subjective assessment of market yields by the Investment Committee

based on various factors like traded prices, reported prices, market conditions

subject to adherence to principles of fair valuation. All securities are valued at a

suitable spread to their respective base curves.

Notes:

1. All MFs will be valued as per NAV provided by respective AMC.

2. All outlier trades will be excluded after suitable justification by Portfolio Manager

and approval of Investment Committee.

Valuation of Debt & Debt Related Instruments for Advisory Clients:

The valuation for advisory clients will be on prudent valuation norms as mutually agreed

upon by Portfolio Manager and the client.


Page 29 of 34

2. Equity

Investment in shares will be valued on the basis of closing market prices of the

National Stock Exchange of India Ltd. If securities are not listed on the National

Stock Exchange of India Ltd., then the closing market prices on the Bombay

Stock Exchange Ltd or on any other exchange on which the securities are listed

will be considered for valuation. Investment in Mutual Fund will be valued on

the basis of daily NAV provided by the concerned Mutual Fund.

Realized gains/losses will be on the basis of FIFO (First in First out)

For derivative transactions (if any) unrealized gains and losses on open

positions will be calculated by the mark to market method.

Dividends on shares and mutual fund units, interest on debt instruments shall

be accounted on accrual basis.

4. Books of accounts would be separately maintained in the name of the client as are necessary

to account for the assets and any additions, income, receipts and disbursements in

connection therewith as provided under SEBI (Portfolio Managers) Regulations, 1993.

5. Audit

a. The Portfolio accounts of the Portfolio Manager shall be audited annually by an

independent chartered accountant and a copy of the certificate issued by the chartered

accountant shall be given to the client.

b. The client may appoint a chartered accountant to audit the books and accounts of the

Portfolio Manager relating to his transactions. Such appointment of an independent

Chartered Accountant will be at the cost of the client and Portfolio Manager shall be

entitled to a copy of the Audit Report and the Portfolio Manager shall co-operate with

such chartered accountant in course of the audit. It is also clarified that the aforesaid is

not applicable to clients who have availed only Advisory Portfolio Management Services.


Page 30 of 34

17. Termination of Agreement

1. Notwithstanding anything contained above, the funds or securities can be withdrawn or

taken back by the client before maturity of the contract under the following circumstances,

namely –

a. Voluntary or compulsory termination of portfolio management services by the Portfolio

Manager or the client.

b. Suspension or cancellation of the certificate of registration of the Portfolio manager by

the Board.

c. Bankruptcy or liquidation of the Portfolio Manager.

2. There shall be written intimation about such termination by the terminating party.

3. On termination of the agreement, the Portfolio Manager shall give a detailed statement of

accounts to the client and settle the account with the client as agreed in the agreement.

18. Disclaimer by Portfolio Manager

Prospective investors should review / study this Disclosure Document carefully and in its entirety

and shall not construe the contents hereof or regard the summaries contained herein as advice

relating to legal, taxation, or financial / investment matters and are advised to consult their own

professional advisor(s) as to the legal, tax, financial or any other requirements or restrictions

relating to the subscription, gifting, acquisition, holding, disposal (sale or conversion into money)

of Portfolio and to the treatment of income (if any), capitalization, capital gains, any distribution,

and other tax consequences relevant to their portfolio, acquisition, holding, capitalization,

disposal (sale, transfer or conversion into money) of portfolio within their jurisdiction of

nationality, residence, incorporation, domicile etc. or under the laws of any jurisdiction to which

they or any managed funds to be used to purchase/gift portfolio of securities are subject, and

also to determine possible legal, tax, financial or other consequences of subscribing / gifting,

purchasing or holding portfolio of securities before making an investment.


Page 31 of 34

19. Investors’ services

The following person shall attend to the investor queries and grievances.

Name :- Mr. Balkrishna A. Shah

Designation :- Compliance Officer,

Correspondence :- 1101-1102, Naman Centre,

Address: :- G – Block, C– 31,

Bandra Kurla Complex,

Bandra (East) – Mumbai – 400 051.

Phone No :- 022-40845000.

Email address :- [email protected]

Dedicated email address for customer grievances : - [email protected]

The investor relations officer mentioned above will ensure prompt Redressal of investor queries

and grievances and shall be empowered by the Portfolio Manager with necessary authority,

means and independence to do so.

20. Grievance Redressal and Dispute settlement mechanism

The Portfolio Manager through the investor relation officer shall attend to and address any

clients’ queries and concerns as soon as possible to mutual satisfaction and within reasonable

period of time.

Name :- Mr. Balkrishna A. Shah

Designation :- Compliance Officer

Correspondence :- 1101-1102, Naman Centre,

Address: :- G – Block, C– 31,

Bandra Kurla Complex,

Bandra (East) – Mumbai – 400 051.

Phone No: :- 022-40845000

Email address :- [email protected]


Page 32 of 34

Dedicated email address for customer grievances :- [email protected]

The above-mentioned officer shall attend to the grievances of the client.

Investor may approach the abovementioned officers directly for any dispute/complaints they

may have against the company.

Alternatively, with effect from September 2011, SEBI has launched a new web based centralized

grievance system called SCORES i.e. SEBI Complaints Redressal System, for online filing,

forwarding and tracking of resolution of investor complaints. The Client may also make use of the

SCORES facility for any escalations on redressal of their grievances. Following is the link to visit

the website and inform their dispute/complaints against the company.

http://scores.gov.in/Complaint.aspx?flag=n

SEBI vide press release PR No. 80/2012 dated 30th

August’ 2012 has extended its toll free helpline

service for Investors (1800 22 7575 / 1800 266 7575) to Saturday and Sunday from the existing

Monday to Friday. The service on Saturday and Sunday would be available initially to investors

from all over India in English, Hindi, Marathi and Gujarati from 9:30 a.m. to 5:30 p.m. For any

queries/ feedback or assistance, the Client may also e-mail to [email protected]

The agreement with the client shall be governed by construed and enforced in accordance with

the laws of India.

Arbitration:

Any dispute with the client shall at first be settled by mutual discussion, failing which the same

will be referred to and settled by arbitration in accordance subject to the provisions of the

Arbitration and Conciliation Act, 1996 or any statutory modification / enactment thereof for the

time being in force. A sole arbitrator will be appointed by mutual consent of the portfolio

manager and the client. The arbitration shall be held in Mumbai and be conducted in English

language. Any action or suit involving the agreement with a client or the performance of the

agreement by the either party of its obligations will be exclusively in courts located at any place

in India subject to the jurisdiction clause in the portfolio agreement.


Page 33 of 34

21. Other Disclosures by Portfolio Manager:

1. The Company may avail services of other associates or group companies as empanelled broker

or for other services such as executing transactions on behalf of clients at arm’s length basis.

2. The Company may undertake proprietary trading in its independent capacity in other divisions in

Debt Market or Capital Market Segment.

3. The Portfolio Manager may invest the Portfolio in such IPOs/FPOs/Private Placements/Fixed

Deposit and other financial products where it is acting as a Lead Manager or renders advisory

services in fund raising. The Portfolio Manager may also avail the brokerage fees out of such

transaction.

4. The TIAPL/Associates/group companies may get commission as a distributor of financial

products including mutual fund for investment made on behalf of clients in Portfolio Products.

22. List of Approved Share Brokers, involved for Portfolio Management activities

Sr.

No.

Name SEBI

Registration

No.(NSE Cash)

SEBI Registration

No.(NSE

Derivatives)

SEBI

Registration

No.(BSE Cash)

SEBI

Registration

No.(BSE

Derivatives)

1. Trust Financial

Consultancy Services

Pvt. Ltd.

INB231198731 INF231198731 INB011198737 INF011198737

2. BSV Securities Pvt. Ltd.

INB231222036 INF231222036 INB011222032 INF011222032

3. Antique Stock Broking

Ltd

INB231298739 INF231298739 INB011298933 INF011298933

4. Motilal Ostwal

Securities Limited

INB231041238 INF231041238 INB011041257 INF011041257

5. Ambit Capital Pvt. Ltd.

INB231247637 INF231247637 INB011247633 INF011247633

6. Spark Capital Advisors

(India) Pvt. Ltd

INB231256232 INF231256232 INB011256238 INF011256238


Page 34 of 34

23. General

The portfolio manager and the client can mutually agree to be bound by specific terms through a

written two-way agreement between themselves in addition to the standard agreement.

For Trust Investment Advisors Pvt. Ltd.

Sd/- Sd/-

Nipa Sheth Nisha Mehta

Director Director

Mumbai :- 4th

July, 2016.

trust investment advisors pvt. ltd. - … · trust investment advisors pvt. ltd. portfolio...

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