Investment Charter

SECTION 1: VISION AND MISSION

1.1 Vision Statement

“BE FINANCIALLY FIT” – To be the trusted financial partner for life, helping clients achieve financial freedom through disciplined, goal-based investment strategies.

1.2 Mission Statement

To provide independent, unbiased investment advisory services that enable our clients to:

• Invest with knowledge and safety
• Achieve their life goals through customized financial solutions
• Build and preserve wealth across generations
• Develop financial literacy and make informed investment decisions

1.3 Core Values

• Trust: Building lifelong relationships through integrity and transparency
• Compliance: Adhering to the highest regulatory and ethical standards
• Ethics: Acting always in the best interests of our clients
• Excellence: Delivering superior service through expertise and innovation

SECTION 2: REGULATORY FRAMEWORK AND COMPLIANCE

2.1 Regulatory Authority

Banconus operates under the regulatory oversight of the Securities and Exchange Board of India (SEBI) and complies with:

• SEBI (Investment Advisers) Regulations, 2013
• SEBI (Investment Advisers) Amendment Regulations, 2024
• All applicable circulars and guidelines issued by SEBI

2.2 Registration Details

• Entity Type: Private Limited Company
• Registration Category: Investment Adviser
• CIN: U67190TN2010PTC077211
• Incorporation Date: September 2, 2010
• Registered Address: Flat No.10, 4th Floor, Shri Kaladhara, No.9/12, Alexandria Road, Cantonment, Trichy – 620001

2.3 Professional Qualifications

Leadership Team:

• Rajee Venkatesan: Chartered Accountant (All India Topper), Financial Planner (15+ years), SEBI-certified by Financial Planning Standards Board of India
• Ramakrishnan Ananthakrishnan: Chartered Accountant, MBA (Ross Business School & London Business School), Former MD/CFO Asia Pacific JP Morgan Hong Kong
• Giri Venkatesh: ….

SECTION 3: INVESTMENT PHILOSOPHY AND APPROACH

3.1 Core Investment Philosophy

Our investment philosophy is grounded in the principle that “investing is not the study of finance, but the study of how people behave with money.” We believe in:

1. Goal-Based Investment Planning: Money is a tool to achieve life goals, not an end in itself
2. Long-term Wealth Creation: Patient capital deployment for sustainable growth
3. Risk-Adjusted Returns: Balancing risk and return based on individual client profiles
4. Behavioral Finance Awareness: Understanding and mitigating behavioral biases
5. Asset Allocation Primacy: Strategic asset allocation as the primary driver of long-term returns

3.3

3.2 Investment Process

Our systematic investment process follows these steps:

1. Goal Identification: Understanding client’s life goals and financial objectives
2. Risk Profiling: Comprehensive assessment of risk appetite and capacity
3. Asset Allocation: Strategic and tactical asset allocation based on goals and risk profile
4. Investment Selection: Careful selection of investment products across asset classes
5. Implementation: Systematic execution of the investment strategy
6. Monitoring and Review: Regular performance monitoring and periodic rebalancing

SECTION 4: FIDUCIARY RESPONSIBILITIES

4.1 Fiduciary Duties

As a registered investment adviser, Banconus acknowledges and commits to the following fiduciary duties:

4.1.1 Duty of Loyalty

• Act solely in the best interests of clients
• Avoid conflicts of interest or disclose them transparently
• Maintain independence in investment recommendations
• Prioritize client interests over company interests

4.1.2 Duty of Care

• Exercise professional competence and diligence
• Conduct thorough research and analysis
• Provide suitable investment advice based on client circumstances
• Maintain current knowledge of market conditions and regulations

4.1.3 Duty of Good Faith

• Provide honest and transparent communication
• Disclose all material information affecting investment decisions
• Maintain confidentiality of client information
• Act with integrity in all professional dealings

4.2 Investment Standards

• Prudent Investor Rule: Exercise care, skill, prudence, and diligence
• Diversification: Maintain appropriate portfolio diversification
• Cost Consciousness: Consider investment costs in all recommendations
• Documentation: Maintain comprehensive records of all investment decisions

SECTION 5: CLIENT SERVICE STANDARDS

5.1 Client Onboarding

• Comprehensive Know Your Customer (KYC) process
• Detailed risk profiling and suitability assessment
• Clear documentation of investment advisory agreement
• Transparent fee disclosure and conflict of interest statements

5.2 Ongoing Client Service

• Regular portfolio reviews and performance reporting
• Proactive communication on market developments
• Annual financial health checks
• Educational support through “Money Matters” program

5.3 Service Commitments

• Response Time: Acknowledge client queries within 24 hours
• Reporting: Quarterly performance reports and annual comprehensive reviews
• Accessibility: Multiple communication channels including digital platforms
• Transparency: Clear, jargon-free communication on all matters

SECTION 6: INVESTMENT UNIVERSE AND ASSET CLASSES

6.1 Permitted Asset Classes

Banconus may recommend investments across the following asset classes:

6.1.1 Equity Investments

• Large-cap, mid-cap, and small-cap equity mutual funds
• Sectoral and thematic equity funds
• International equity funds
• Exchange-traded funds (ETFs)

6.1.2 Fixed Income Investments

• Government securities and bonds
• Corporate bonds and debentures
• Debt mutual funds across duration and credit spectrum
• Fixed deposits and other bank products

6.1.3 Alternative Investments

• Gold ETFs and gold mutual funds
• Real Estate Investment Trusts (REITs)
• Infrastructure Investment Trusts (InvITs)
• Portfolio Management Services (PMS)

6.1.4 Other Investments

• Money market instruments
• Overseas investment products (within regulatory limits)
• Insurance-linked investment products (ULIPs)

6.2 Investment Restrictions

• No direct investment in individual stocks (for regular advisory clients)
• No investment in speculative or unregulated products
• No leveraged investments unless specifically suitable and disclosed
• No investment in products with hidden charges or poor governance

SECTION 7: RISK MANAGEMENT FRAMEWORK

7.1 Risk Identification

We identify and manage the following categories of risk:

7.1.1 Market Risk

• Systematic risk from overall market movements
• Unsystematic risk from specific investments or sectors
• Interest rate risk affecting bond investments
• Currency risk from international investments

7.1.2 Liquidity Risk

• Ensuring adequate liquidity for client needs
• Monitoring investment liquidity profiles
• Maintaining emergency fund recommendations

7.1.3 Operational Risk

• Process failures and human errors
• Technology and system risks
• Regulatory and compliance risks
• Counterparty and credit risks

7.2 Risk Management Procedures

• Regular stress testing of client portfolios
• Diversification across asset classes, geographies, and time horizons
• Continuous monitoring of risk metrics
• Periodic review and adjustment of risk parameters

7.3 Risk Tolerance Assessment

• Comprehensive risk profiling questionnaire
• Assessment of risk capacity based on financial situation
• Evaluation of risk willingness and behavioral factors
• Regular reassessment based on changing circumstances

SECTION 8: PERFORMANCE MEASUREMENT AND BENCHMARKING

8.1 Performance Objectives

• Achieve risk-adjusted returns superior to appropriate benchmarks
• Meet or exceed client-specific return requirements
• Maintain downside protection during market stress
• Optimize after-tax returns for taxable clients

8.2 Benchmarking Standards

Performance will be measured against:

• Relevant market indices for each asset class
• Peer group comparisons for similar strategies
• Client-specific financial planning targets
• Risk-adjusted performance metrics (Sharpe ratio, Sortino ratio)

8.3 Reporting Framework

• Monthly NAV and portfolio updates
• Quarterly performance and attribution reports
• Annual comprehensive portfolio review
• Goal-based progress tracking and reporting

SECTION 9: GOVERNANCE STRUCTURE

9.1 Board and Management

• Managing Directors: Rajee Venkatesan and Ramkey Narayanan
• Investment Committee: Senior partners review investment strategies quarterly
• Compliance Officer: Ensures adherence to regulatory requirements
• Operations Team: Six-member back office supporting client services

9.2 Investment Committee Responsibilities

• Review and approve investment strategies and policies
• Monitor portfolio performance and risk metrics
• Evaluate and select investment products and managers
• Ensure compliance with investment guidelines and regulations

9.3 Decision-Making Process

• Collaborative approach between partners
• Research-driven investment decisions
• Client-centric customization of recommendations
• Regular review and validation of investment thesis

SECTION 10: FEE STRUCTURE AND TRANSPARENCY

10.1 Fee Philosophy

Our fee structure is designed to:

• Align our interests with client success
• Provide transparent and fair pricing
• Ensure value for money across all service levels
• Avoid conflicts of interest from commission-based products

10.2 Fee Structure

• Asset-based advisory fees charged as percentage of assets under management
• Transparent fee disclosure in investment advisory agreements
• No hidden charges or commissions from product manufacturers
• Preferential fees for long-term client relationships

10.3 Fee Disclosure

• Complete fee disclosure before client onboarding
• Annual summary of all fees paid by clients
• No trail commissions or undisclosed payments
• Clear explanation of fee calculation methodology

SECTION 11: CONFLICT OF INTEREST MANAGEMENT

11.1 Identification of Conflicts

Potential conflicts of interest may arise from:

• Personal investments by partners and employees
• Relationships with product manufacturers
• Business partnerships or affiliations
• Client referral arrangements

11.2 Conflict Management Procedures

• Complete disclosure of all potential conflicts
• Maintenance of personal trading policies for employees
• Independent investment research and analysis
• Client interest prioritization in all decisions

11.3 Related Party Transactions

• Prohibition of self-dealing in client portfolios
• Arm’s length transactions for any related party dealings
• Board approval for material related party transactions
• Transparent disclosure of any related party relationships

SECTION 12: CLIENT PROTECTION AND GRIEVANCE REDRESSAL

12.1 Client Protection Measures

• Comprehensive client agreement outlining rights and responsibilities
• Regular communication and portfolio updates
• Protection of client confidential information
• Segregation of client assets and company assets

12.2 Grievance Redressal Mechanism

• Internal Process:
  • Primary contact: Relationship Manager
  • Escalation to: Managing Directors
  • Resolution timeframe: 30 days
• External Forums:
  • SEBI SCORES platform
  • BSE Investor Grievance mechanism
  • Consumer courts and arbitration

12.3 Client Rights

• Right to receive suitable investment advice
• Right to transparent fee disclosure
• Right to portfolio information and reports
• Right to exit advisory relationship with notice

SECTION 13: TECHNOLOGY AND OPERATIONAL INFRASTRUCTURE

13.1 Technology Platform

• Comprehensive portfolio management system
• Real-time market data and analysis tools
• Secure client communication and reporting platform
• Digital onboarding and KYC processes

13.2 Data Security and Privacy

• Robust cybersecurity measures and protocols
• Confidentiality of client information
• Regular backup and disaster recovery procedures
• Compliance with data protection regulations

13.3 Business Continuity

• Contingency plans for operational disruptions
• Remote working capabilities and procedures
• Alternative communication channels
• Regular testing of business continuity plans

SECTION 14: PROFESSIONAL DEVELOPMENT AND EDUCATION

14.1 Continuous Learning

• Regular professional development for all team members
• Attendance at industry conferences and seminars
• Subscription to research and market intelligence services
• Ongoing regulatory and compliance training

14.2 Client Education

• “Money Matters” Program: Financial literacy initiative
• Regular educational workshops and webinars
• Market commentary and investment insights
• Goal-based financial planning education

14.3 Industry Engagement

• Active participation in industry associations
• Contribution to financial literacy initiatives
• Thought leadership through blogs and publications
• Mentoring professionals in the industry

SECTION 15: ENVIRONMENTAL, SOCIAL, AND GOVERNANCE (ESG) CONSIDERATIONS

15.1 ESG Integration

• Incorporation of ESG factors in investment analysis
• Preference for well-governed companies and funds
• Consideration of sustainability in long-term investment decisions
• Client education on responsible investing

15.2 Sustainable Investing Options

• ESG-focused mutual funds and ETFs
• Impact investing opportunities where appropriate
• Screening for environmental and social factors
• Engagement with fund managers on ESG practices

SECTION 16: CHARTER REVIEW AND AMENDMENTS

16.1 Regular Review

This Investment Charter will be reviewed annually or when:

• Significant changes in regulatory requirements occur
• Material changes to business operations are implemented
• Changes in senior management or ownership structure
• Client feedback indicates need for modifications

16.2 Amendment Process

• Proposals for amendments must be approved by both Managing Directors
• Material changes require documentation and client notification
• All amendments must maintain regulatory compliance
• Updated charter must be communicated to all stakeholders

16.3 Effective Date and Communication

• All amendments effective upon approval unless otherwise specified
• Clients notified of material changes within 30 days
• Updated charter published on company website
• Training provided to staff on any procedural changes

SECTION 17: SIGNATURES AND ACKNOWLEDGMENT

This Investment Charter represents the commitment of Banconus Financial Solutions Private Limited to maintain the highest standards of investment advisory services, fiduciary duty, and client care.

Acknowledged and Approved by:

Rajee Venkatesan
Managing Director & Co-Founder
Chartered Accountant, Certified Financial Planner
Date: _________________ Signature: _________________

Ramkey Narayanan
Managing Director & Co-Founder
Chartered Accountant, MBA
Date: _________________ Signature: _________________

APPENDICES

Appendix A: Regulatory References

• SEBI (Investment Advisers) Regulations, 2013
• SEBI Investor Charter for Investment Advisers (Circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/80)
• SEBI Master Circular for Investment Advisers, 2024

Appendix B: Contact Information

• Chennai Office: 2A Krishna Apartments, No.20, Luz Avenue Road, Alwarpet, Chennai 600004
• Trichy Office: Flat No.10, 4th Floor, Shri Kaladhara, No.9/12, Alexandria Road, Cantonment, Trichy – 620001
• Phone: +91 97910 13402
• Email: info@banconus.com
• Website: https://banconus.com

Appendix C: Investor Grievance Information

• Internal Grievance Officer: Managing Directors
• SEBI SCORES: https://scores.sebi.gov.in
• BSE Investor Protection Fund: https://www.bseindia.com
• Ombudsman Details: [To be updated as applicable]