Investor Grievance Redressal | julyventures.com

Introduction

The objective and purpose of JVF is to carry on the activity of running and managing AIFs and for this

purpose to arrange, make, manage and dispose of investments with the view to providing returns to the

investors in accordance with Scheme Documents, Trust Documents and applicable Laws.

Effective Date

This policy will be effective from the date of First Closing of each scheme as defined in respective

Scheme Documents and communication to SEBI.

As per SEBI’s circular no. CIR/OIAE/1/2014 dated December 18,2014, investor grievance redress

mechanism has to be followed by all AIFs.

Purpose

Investor service is a vital element for sustained business growth, and it will be JVF’s aim to ensure that its

investors receive exemplary service across different touch points of the fund cycle. Prompt and efficient

service is essential to retaining existing relationships and therefore investor satisfaction becomes critical.

Investor queries and complaints constitute an important voice of Investor, and this policy details

grievance handling through a structured grievance redressal framework. Grievance redressal is supported

by a review mechanism, to minimise the recurrence of similar issues in future.

This policy sets out the grievance redressal policy (Policy) that will be followed by the Investment

Manager in the event of an investor/s grievance/s. Grievances include allegations such as failure to

drawdown, disclose conflicts of interest, misrepresentations, etc. and complaints regarding processing of transactions, distribution of units etc. Investor feedbacks, queries/ clarifications will not be considered as

instances of complaint or grievance.

Investor queries and complaints constitute an important voice of investors, and this Policy details

grievance handling through a structured grievance redressal framework. Grievance redressal is supported

by are view mechanism, to minimise the recurrence of similar issues in the future.

Obligations, Roles and Responsibilities of the Investment Manager

The IM shall appoint a “Compliance Officer” who shall be responsible for the implementation and supervision of this policy
The Investor Relation Officer shall assist and report to the Compliance Officer on a daily basis in respect of Investor Grievance received and redressed.
The Compliance Officer shall take all the necessary steps to monitor, document, analyse and report the findings to the IM and respective regulatory bodies as required by the SEBI (AIF) Regulations, other Scheme Documents and this Policy document.
The Compliance Officer shall exercise his/her judgement in consultation with the IM and take adequate precautions to ensure implementation of an effective monitoring mechanism.
The Internal Auditor and the PPM Auditor of the Fund shall review the implementation, documentation and effectiveness and review the actions taken during the period of audit and shall record the observations with respect to the same in their reports.
The IM shall peruse, review and provide necessary guidance with regard to the Investor Redressal Grievance Policy, periodically, for strengthening the process.

Principles of the Redressal Policy

Investors shall be treated fairly at all the times.
Complaints raised by the investors shall be dealt with courtesy and in timely manner.
Investors shall be informed of avenues to raise their queries and complaints within the organization, and their rights if they are not satisfied with the resolution of their complaints.
Queries and complaints shall be treated efficiently and fairly.
The employees of the IM shall work in good faith and without prejudice, towards the interests of the Investors.
The IM has a dedicated Grievance Redressal Team under overall supervision of the Compliance Officer who is responsible for timely and prompt communication with the investors, while having an open attitude towards service recovery, and providing alternate solutions to investors, thus ensuring healthy relationships with our investors.

Awareness of Grievance Redressal Mechanism

Transparency: The “Investor” to be provided within formation regarding the channels to convey and resolve their issues. In addition, if the resolution is expected to take longer time, same should be communicated to the Investor.
Accessibility: The IM will enable the Investors to communicate their complaints/ issues and avail redressal services through multiple channels.
Escalation: Information on the process of escalation of complaints to higher level, in case the Investor is not satisfied with the resolution provided by the current person handling the same.
Investors can lodge a complaint for non-receipt of any right available to them or failure of the IM to comply with any statutory obligation as per the scheme documents by giving details of their name, Client ID, nature and full particulars of their complaint directly to the Investor Relation Officer.
The Investor Relation Officer who is receiving the query/complaint is responsible for the resolution of query/ complaint. The Investor Relation Officer at the first level is responsible for ensuring that query/complaint is resolved to the satisfaction of the client, however if the client remains unsatisfied then he/she can escalate the issue through the grievance redressal mechanism.
All the queries/complaints received shall be handled and coordinated by Investor Relation Officer and shall inform the investor on the status of their query. Investors are requested to approach the Investor Relation Officer on any business day between 9 AM to 5 PM to provide feedback and register their queries/ complaints.
Investors can write to Compliance Officer if they do not receive any response within 7 business days of writing to the Investor Grievance Officer of if/he or she is not satisfied with the response received. The Investor can expect a reply within 7 business days of approaching the Compliance Officer.
In case the Investors are not satisfied with the response of the Compliance Officer, they can escalate it ahead to the Investment Manager.
If the Investors do not receive a response within 30 business days of approaching the Investment Manager or if they are not satisfied with the resolution received for the Compliance Officer and the IM, they can escalate their issues to SEBI through its redressal platform SEBI Complaints Redress System (“SCORES”).
In circumstances where the Investors have issue with the Investment Manager, they can write to the Trustee giving the details of the compliant. Within the rights of the Trustee as per the terms of the Private Placement Memorandum and other Scheme Documents, it shall resolve the grievance by taking appropriate measures. The investor can expect a reply within 10 business days of approaching the Trustee. In cases where the grievance is outside the purview of the Trustee or if the Investor is not satisfied with the resolution from the Trustee, then he/she may approach to SEBI through its redressal platform, SCORES.