Code of Conduct for Cat-1 EOPs

A. General

(1) Integrity:

As an entity registered with AMFI as Category-1 Execution Only Platform (EOP), we will maintain high standards of integrity, promptitude and fairness in the conduct of our business.

(2) Exercise of due skill and care:

We as an EOP will act with due skill, care and diligence in the conduct of our business, and shall ensure that we and our personnel will act in an ethical manner in all the dealings with investors.

(3) Compliance with statutory requirements:

We, as an EOP, will abide by all the applicable rules, regulations and guidelines issued by the Government, SEBI and AMFI.

B. Duty to the investors

(1) KYC Compliance:

We as an EOP, will onboard only such investors who have completed the KYC process.

(2) Dealing with investors:

We as an EOP, in all our dealings with the general investing public and investors shall treat all investors fairly and equally and shall not discriminate between different investors or refuse to deal with a small ticket investor merely on the grounds of the volume of business involved.

(3) Execution of Orders & Transaction confirmation:

We, as an EOP, will execute the investors’ orders for transactions in mutual fund units immediately upon the investor placing the order and notify the investor about the successful execution or failure thereof for any reason. The transaction data will be sent to the respective RTA immediately upon the investor executing an order without any delay (i.e., we will not bunch or accumulate the investors’ transactions and send in batches)

(4) Confidentiality of Investor’s data:

We, as an EOP will not misuse, disclose or share the investor’s personal data or details of investments which comes to our possession in the course of our business relationship with any third party or group companies without explicit and express written consent of the investor which may be obtained electronically. In case the investor’s consent is obtained electronically, the menu shall prompt the investor to specifically provide consent (i.e., through an informed decision) and not by way of any passive / default option. We will preserve these electronic logs of such consent with us. We will also provide a facility to withdraw such consent to the investors.

In this context, we as an EOP and our personnel will abide by the ‘Data Sharing Principles’ prescribed by AMFI and the applicable laws on personal data protection. We will adhere to contractual agreements with the asset management companies (AMCs) relating to data privacy to ensure that the investors’ data is always protected, used only for the purpose for which it was obtained and purged as soon as the data is no longer required to be stored for rendering services for which it was collected or stored securely.

(5) Fairness to Investors & Handling of Conflict of Interest:

We as an EOP, when dealing with an investor, will disclose that we are acting as an Agent of the AMCs with whom we have tied up. We shall avoid conflict of interest and will make adequate disclosure of our interest to the investor. In the event of a conflict of interest, we will inform the investor accordingly and shall take reasonable steps to resolve the same in an equitable manner and shall not seek to gain a direct or indirect personal advantage from the situation and shall not consider investors’ interest inferior to our own.

We will comply with the provisions w.r.t. ‘Handing of Conflict of Interest’ as prescribed in clause 8 of the SEBI Circular no. SEBI/HO/IMD/IMD-PoD-1/P/CIR/2023/86 dated June 13, 2023.

(6) Investment Advice:

We, as an EOP or any of our employees will not render, directly or indirectly, any investment advice about any mutual fund scheme/s either on our own or in any other publicly accessible media, whether real-time or otherwise, nor make any recommendation to any investor for purchase or redemption of Units of any mutual fund scheme.

(7) Competence:

We, as an EOP, shall have adequately trained staff and arrangements to render fair, prompt and competent services to our investors as well as appropriate grievance redressal mechanism.

(8) Grievance Redressal Mechanism:

We, as an EOP, will put in place an appropriate grievance redressal mechanism and endeavor to resolve the investor grievances/complaints arising out of our EOP activities promptly and shall provide complete assistance to the investor and the AMCs for redressal of grievances/ complaints. We will disclose the grievance redressal mechanism on our website and mobile application.

(9) Technological Infrastructure:

We as an EOP, will ensure that we have the appropriate/ necessary and robust technological infrastructure and the capability to provide digital technology platform at all times to facilitate execution of online transactions in mutual funds, including appropriate cyber security measures to ensure security of electronic data during collection, transmission and storage as well as to mitigate risks related to execution of Mutual Fund transactions through our platform. Our Platform will be scalable with robust cyber security protocols and supported through an API-based architecture. We will put in place necessary Business Continuity Process (BCP) and Disaster Recovery (DR) to ensure uninterrupted service to the investors and the AMCs /in case of any disruptions / break-down / down time. We will comply with technology related requirements as prescribed in clause 9 the aforesaid SEBI Circular.

(10) Advertisement and Publicity:

We as an EOP will not advertise our business publicly unless permitted by AMFI / SEBI and shall abide by the advertisement guidelines issued by AMFI/ SEBI.

(11) Inducement of Investors:.

We as an EOP will not rebate or pass-back the transaction fees to the investor and will refrain from attracting investors through inducement of rebate or gifts / gift-vouchers or any such other means. We will not resort to unfair means of inducing investors from shifting from other EOPs to our platform.

(12) Net-worth:

We, as an EOP will fulfil the net-worth criteria, as specified at all times.

(13) We as an EOP, will ensure that any change in our registration status (owing to any penal action taken by AMFI or otherwise) or any material change in our financials which may adversely affect the interests of investors, is promptly informed to the investors and any business remaining outstanding is transferred to another registered EOP in accordance with the instructions of the affected investors/ investors.

C. Obligations towards integrity of the Mutual Fund industry:

(1) We as an EOP and our employees will observe high standards of integrity and consistently conduct our dealings in a manner to uphold the professional image of the Mutual Fund industry.

(2) We as an EOP, will refrain from making false or defamatory statements about any AMC, AMFI, Mutual Fund schemes or other EOPs and/or market intermediaries in any private or public forum (including chat groups, social media, print or electronic press, conferences etc.).

(3) We as an EOP, will maintain professional decorum, provide fair and balanced perspective and not participate in transmitting untrue statements or rumours so as to malign any AMC or Mutual Fund scheme or bring disrepute to any AMC, AMFI or the Mutual Fund industry. Any written or oral communication will be based on verifiable facts and will be presented in an unbiased manner so as not to mislead the public.

(4) Unfair trade practices: We as an EOP will not indulge in any manipulative, fraudulent, deceptive or unfair trade practices or spread rumours with a view to distorting market equilibrium or making personal gains.

(5) Submission of Reports /returns: We as an EOP will ensure timely submission of not neglect or fail or refuse to submit any required report or returns and not make any false or misleading statement on any report or returns which may be required to be submitted to the AMCs or AMFI.