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Investor Charter - Annexure A
A. Vision and Mission Statements for investors
Vision
Invest with knowledge and safety.
Mission
Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.
B. Details of business transacted by the Investment Adviser with respect to the investors
To enter into an agreement with the client providing all details including fee details, aspects of Conflict of interest disclosure and maintaining confidentiality of information.
To do a proper and unbiased risk – profiling and suitability assessment of the client.
To conduct audit annually.
To disclose the status of complaints on its website.
To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details (i.e. Head office/ regional/ local Office) on its website.
To employ only qualified and certified employees.
To deal with clients only from official number
To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.
To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers
Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by investment adviser.
C. Details of services provided to investors (No Indicative Timelines)
- Onboarding of Clients
- Sharing of agreement copy
- Completing KYC of clients
- Disclosure to Clients
- To provide full disclosure about its business, affiliations, compensation in the agreement.
- To not access client’s accounts or holdings for offering advice.
- To disclose the risk profile to the client.
- To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.
- To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.
- To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.
- To treat all advisory clients with honesty and integrity.
- To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.
- To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services.
- To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.
- To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines.
D. Details of grievance redressal mechanism and how to access it
- Investor can lodge complaint/grievance against Investment Adviser in the following ways:
- Mode of filing the complaint with investment adviser
In case of any grievance/complaint, an investor may approach the concerned Investment Adviser who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance. - Mode of filing the complaint on SCORES or with Investment Adviser Administration and Supervisory Body (IAASB)
- SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://play.google.com/store/apps/details?id=com.sebi&pcampaignid=web_share)
Two level review for complaint/grievance against investment adviser:
- First review done by designated body (IAASB)
- Second review done by SEBI
- Email to designated email ID of IAASB
- SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://play.google.com/store/apps/details?id=com.sebi&pcampaignid=web_share)
- Mode of filing the complaint with investment adviser
E. Rights of Investors
- Right to Privacy and Confidentiality
- Right to Transparent Practices
- Right to fair and Equitable Treatment
- Right to Adequate Information
- Right to Initial and Continuing Disclosure
- Right to receive information about all the statutory and regulatory disclosures.
- Right to Fair & True Advertisement
- Right to Awareness about Service Parameters and Turnaround Times
- Right to be informed of the timelines for each service
- Right to be Heard and Satisfactory Grievance Redressal
- Right to have timely redressal
- Right to Suitability of the Financial Products
- Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
- Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
- Additional Rights to vulnerable consumers
- Right to get access to services in a suitable manner even if differently abled
- Right to provide feedback on the financial products and services used
Right against coercive, unfair, and one-sided clauses in financial agreements
F. Expectations from the investors (Responsibilities of investors)
Do's
- Always deal with SEBI registered Investment Advisers.
- Ensure that the Investment Adviser has a valid registration certificate.
- Check for SEBI registration number.
- Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13
- Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:
- Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.
You may make payment of advisory fees through Centralised Fee Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism. - Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
- Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
- Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
- Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
- Be vigilant in your transactions.
- Approach the appropriate authorities for redressal of your doubts / grievances.
- Inform SEBI about Investment Advisers offering assured or guaranteed returns.
- Always be aware that you have the right to exit the service of an Investment Adviser
- Always be aware that you have the right to seek clarifications and clear guidance on advice
- Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
- Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.
Don'ts
- Don’t fall for stock tips offered under the pretext of investment advice.
- Do not provide funds for investment to the Investment Adviser.
- Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don’t let greed overcome rational investment decisions.
- Don’t fall prey to luring advertisements or market rumors.
- Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
- Don’t take decisions just because of repeated messages and calls by Investment Advisers.
- Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
- Don’t rush into making investments that do not match your risk taking appetite and investment goals.
- Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.
Investor Charter - Annexure B & Annexure C
Complaint data to be displayed by Circle Wealth Advisors Pvt Ltd
Formats for investors’ complaints data to be disclosed monthly by IAs on their website/mobile application:
Annexure C
Data for the month ending August 31, 2026:
| Sr. No | Received From | Pending at the end of last month | Received | Resolved* | Total Pending# | Pending complaints > 3 months | Average Resolution time^(in days) |
|---|---|---|---|---|---|---|---|
|
1 |
Directly from Investors |
0 |
0 |
0 |
0 |
0 |
0 |
|
2 |
Other Sources(if any) |
0 |
0 |
0 |
0 |
0 |
0 |
|
3 |
SEBI (SCORES) |
0 |
0 |
0 |
0 |
0 |
0 |
|
4 |
Grand Total |
0 |
0 |
0 |
0 |
0 |
0 |
Number of complaints received during month against the IA due to impersonation by some other entity:
Note: In case of any complaints received against the IA due to impersonation of the IA by some other entity, the IA may adjust the number of such complaints from total number of received/resolved complaints while preparing the above table. Further, IA must close such impersonation related complaints after following the due process as specified by SEBI/ IAASB.
* Inclusive of complaints of previous months resolved in the current month. Inclusive of complaints pending as on the last day of the month
* Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.
Annexure B
Number of complaints received during month against the IA due to impersonation by some other entity:
Note: In case of any complaints received against the IA due to impersonation of the IA by some other entity, the IA may adjust the number of such complaints from total number of received/resolved complaints while preparing the above table. Further, IA must close such impersonation related complaints after following the due process as specified by SEBI/ IAASB.
* Inclusive of complaints of previous months resolved in the current month. Inclusive of complaints pending as on the last day of the month
* Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.
Trend of Monthly Disposal of Complaints
| Sr. No | Month | Carried forward from previous month | Received | Resolved* | Pending# |
|---|---|---|---|---|---|
| 1 | Sep 2026 | 0 | 0 | 0 | 0 |
| 2 | Aug 2026 | 0 | 0 | 0 | 0 |
| 3 | Jul 2026 | 0 | 0 | 0 | 0 |
| 4 | Jun 2026 | 0 | 0 | 0 | 0 |
| 5 | May 2026 | 0 | 0 | 0 | 0 |
| 6 | Apr 2026 | 0 | 0 | 0 | 0 |
| 7 | Mar 2026 | 0 | 0 | 0 | 0 |
| 8 | Feb 2026 | 0 | 0 | 0 | 0 |
| 9 | Jan 2026 | 0 | 0 | 0 | 0 |
| 10 | Dec 2025 | 0 | 0 | 0 | 0 |
| 11 | Nov 2025 | 0 | 0 | 0 | 0 |
| 12 | Oct 2025 | 0 | 0 | 0 | 0 |
| 13 | Sep 2025 | 0 | 0 | 0 | 0 |
| 14 | Aug 2025 | 0 | 0 | 0 | 0 |
| 15 | July 2025 | 0 | 0 | 0 | 0 |
| 16 | June 2025 | 0 | 0 | 0 | 0 |
| 17 | May 2025 | 0 | 0 | 0 | 0 |
| 18 | April 2025 | 0 | 0 | 0 | 0 |
*Inclusive of complaints of previous months resolved in the current month.
#Inclusive of complaints pending as on the last day of the month.
Trend of Annual disposal of complaints:
| Sr. No | Month | Carried forward from previous year | Received | Resolved* | Pending# |
|---|---|---|---|---|---|
|
1 |
2025 – 26 |
0 |
0 |
0 |
0 |
|
1 |
2024 – 25 |
0 |
0 |
0 |
0 |
|
2 |
2023 – 24 |
0 |
0 |
0 |
0 |
|
3 |
2022 – 23 |
0 |
0 |
0 |
0 |
|
4 |
2021 – 22 |
0 |
0 |
0 |
0 |
*Inclusive of complaints of previous years resolved in the current year.
#Inclusive of complaints pending as on the last day of the year.
Investor Charter - Annexure F
A. Vision and Mission Statements for investors
Vision
Mission
Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and
enjoy financial wellness.
B. Details of business transacted by the Investment Adviser with respect to the investors
- To enter into an agreement with the client providing all details including fee details, aspects of Conflict of interest disclosure and maintaining confidentiality of information.
- To do a proper and unbiased risk – profiling and suitability assessment of the client.
- To conduct audit annually.
- To disclose the status of complaints on its website.
- To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details (i.e. Head office/ regional/ local Office) on its website.
- To employ only qualified and certified employees.
- To deal with clients only from official number
- To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.
- To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers
- Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by investment adviser.
C. Details of services provided to investors (No Indicative Timelines)
- Onboarding of Clients
- Sharing of agreement copy
- Completing KYC of clients
- Disclosure to Clients
- To provide full disclosure about its business, affiliations, compensation in the agreement.
- To not access client’s accounts or holdings for offering advice.
- To disclose the risk profile to the client.
- To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.
- To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.
- To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.
- To treat all advisory clients with honesty and integrity.
- To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.
- To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services.
- To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.
- To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines.
D. Details of grievance redressal mechanism and how to access it
- Investor can lodge complaint/grievance against Investment Adviser in the following ways:
- Mode of filing the complaint with investment adviser
In case of any grievance/complaint, an investor may approach the concerned Investment Adviser who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance. - Mode of filing the complaint on SCORES or with Investment Adviser Administration and Supervisory Body (IAASB)
- SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://play.google.com/store/apps/details?id=com.sebi&pcampaignid=web_share)Two level review for complaint/grievance against investment adviser:
1. First review done by designated body (IAASB)
2. Second review done by SEBI - Email to designated email ID of IAASB
- SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://play.google.com/store/apps/details?id=com.sebi&pcampaignid=web_share)Two level review for complaint/grievance against investment adviser:
- Mode of filing the complaint with investment adviser
- If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.
With regard to physical complaints, investors may send their complaints to:
Office of Investor Assistance and Education,
Securities and Exchange Board of India,
SEBI Bhavan, Plot No. C4-A, ‘G’ Block,
Bandra-Kurla Complex, Bandra (E),
Mumbai – 400 051
E. Rights of Investors
- Right to Privacy and Confidentiality
- Right to Transparent Practices
- Right to fair and Equitable Treatment
- Right to Adequate Information
- Right to Initial and Continuing Disclosure
- Right to receive information about all the statutory and regulatory disclosures.
- Right to Fair & True Advertisement
- Right to Awareness about Service Parameters and Turnaround Times
- Right to be informed of the timelines for each service
- Right to be Heard and Satisfactory Grievance Redressal
- Right to have timely redressal
- Right to Suitability of the Financial Products
- Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
- Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
- Additional Rights to vulnerable consumers
- Right to get access to services in a suitable manner even if differently abled
- Right to provide feedback on the financial products and services used
Right against coercive, unfair, and one-sided clauses in financial agreements
F. Expectations from the investors (Responsibilities of investors)
Do's
- Always deal with SEBI registered Investment Advisers.
- Ensure that the Investment Adviser has a valid registration certificate.
- Check for SEBI registration number.
- Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13
- Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:
- Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.
You may make payment of advisory fees through Centralised Fee Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism. - Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
- Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
- Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
- Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
- Be vigilant in your transactions.
- Approach the appropriate authorities for redressal of your doubts / grievances.
- Inform SEBI about Investment Advisers offering assured or guaranteed returns.
- Always be aware that you have the right to exit the service of an Investment Adviser
- Always be aware that you have the right to seek clarifications and clear guidance on advice
- Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
- Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.
Don'ts
- Don’t fall for stock tips offered under the pretext of investment advice.
- Do not provide funds for investment to the Investment Adviser.
- Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don’t let greed overcome rational investment decisions.
- Don’t fall prey to luring advertisements or market rumors.
- Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
- Don’t take decisions just because of repeated messages and calls by Investment Advisers.
- Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
- Don’t rush into making investments that do not match your risk taking appetite and investment goals.
- Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.
Compliance Audit
| Sr. No. | Financial Year | Compliance Audit Status | Remarks, If any |
|---|---|---|---|
| 1 | FY 2024-25 | Conducted | NA |
| 2 | FY 2023-24 | Conducted | NA |
| 3 | FY 2022-23 | Conducted | NA |
| 4 | FY 2021-22 | NA | NA |
SEBI Disclousre
Complete name of Investment adviser as registered with SEBI
Circle Wealth Advisors Private Limited
Type of Registration
Non – Individual
Registration number, validity of registration
Registration Number INA000016782. dated 21st March 2022 till perpetual.
BSE Membership No: 1788
CIN of the company
Complete Address with Telephone Numbers
Registered office: 701/702, Madhava Building, BKC, Adjacent to Family Court, Bandra Kurla Complex, Bandra East, Mumbai 400051.
Telephone: +91 02228383000
Contact Details of the Principal Officer
Saurabh Subhash Mittal – (Mobile No: 9967067652 and Email id: saurabh@cwa.co.in)
Contact Details of the Compliance Officer
Roopali Pandurang Khadke – (Mobile No: 9975100826 and Email id: compliance@cwa.co.in)
Corresponding SEBI regional/local office address
SEBI Bhavan Bandra Kurla Complex Bandra East Mumbai 400051
Mandatory Disclosure By SEBI
Grievance Redressal
We, at Circle Wealth Advisors Private Limited, are dedicated towards the prosperity of our clients by following our aim of adding meaning to finances and adding time to your life. In the event of a complaint regarding our services we would be more than happy in addressing and solving it in the most proficient manner.
In case of any grievance / complaint against Circle Wealth Advisors Private Limited.
Please contact Compliance Office of Circle Wealth Advisors Private Limited / address of Registered Office :-
Compliance Officer Details
Name: Ms. Roopali Khadke,
Contact No: +91 99751 00826
Email Id: compliance@cwa.co.in
Address of Registered Officer
701/702, Madhava Building, E Block, Bandra Kurla Complex, Near Family Court Bandra East, Mumbai 400051.
You may also approach Saurabh Subhash Mittal, Principle Officer of Circle Wealth Advisors Private Limited on below contact details.
Contact No: 99670 67652
Email Id: saurabh@cwa.co.in
If not satisfied with the response of the intermediary, you can lodge your grievances with SEBI at SCORES mobile application that can be downloaded from below link:
https://play.google.com/store/apps/details?id=com.sebi&pcampaignid=web_share
You may also write to any of the offices of SEBI.
You can also lodge complaint through ODR portal.
“The Parties hereby agree to undertake online conciliation and/or online arbitration by participating in the ODR Portal (accessible at [https://smartodr.in/login]) and/or undertaking dispute resolution in the manner specified in this Circular No. SEBI/HO/OIAE_IAD-1/P/CIR/2023/131.”
For any queries, feedback or assistance, please contact SEBI Office on Top Free Helpline at 1800 22 7575 / 1800 266 7575.
Grievance Redressal / Escalation Matrix
| Details of designation | Contact person name | Address where the physical address location | Contact no | Email-id | Working hours when complainant can call |
|---|---|---|---|---|---|
| Customer Care | Sakshi Shah | 701/702, Madhava Building, E Block, Bandra Kurla Complex, BKC, Bandra East, Mumbai-400051 | 8879493071 | sakshi@cwa.co.in | 10.00 AM to 6.00 PM |
| Head of Customer Care | Sakshi Shah | same as above-mentioned | 8879493071 | sakshi@cwa.co.in | 10.00 AM to 6.00 PM |
| Compliance Officer | Roopali Khadke | same as above-mentioned | 9975100826 | compliance@cwa.co.in | 10.00 AM to 6.00 PM |
| CEO | Mukul H Agarwal | same as above-mentioned | 9833893303 | mukul@cwa.co.in | 10.00 AM to 6.00 PM |
| Principal Officer | Saurabh Mittal | same as above-mentioned | 9967067652 | saurabh@cwa.co.in | 10.00 AM to 6.00 PM |
Disclaimer
Investment Risks
All investments are subject to market risks, including the possible loss of principal. Investors are strongly encouraged to read and understand all relevant information, including associated risks, before making any investment decision. The value of investments may fluctuate due to changes in market conditions. Past performance is not a reliable indicator of future results.
Website and Use of Information
By accessing this website, you acknowledge and agree to the following terms of use. This website is owned and operated by Circle Wealth Advisors Private Limited (CWA) for the purpose of providing general information, promoting financial literacy, and offering educational content.
The content on this website does not constitute an offer, solicitation, or recommendation to buy or sell any financial product or service. Products and services described on this website may not be available in all geographical locations or to all individuals.
Circle Wealth Advisors Private Limited has made every effort to ensure the accuracy and reliability of the information provided; however, we do not guarantee its completeness or timeliness. Any reliance on the information presented is strictly at your own risk. The content of this website should not be used as a basis for personal or financial decisions and does not substitute professional advice.
Limitation of Liability
Circle Wealth Advisors disclaims any liability for any direct, indirect, or consequential loss arising from the use or reliance on the information provided on this website. While we strive to ensure uninterrupted and error-free operation of this site, we do not warrant that the functions or content will operate without errors or technical interruptions.
Third-Party Links
This website may contain links to third-party websites for convenience. Circle Wealth Advisors does not endorse or take responsibility for the content, accuracy, or compliance of such third-party sites with applicable laws. Users are advised to review the terms of use and policies of linked websites independently.
Disclosures
Circle Wealth Advisors Private Limited is a SEBI-registered investment adviser (Registration No.: INA000016782). CWA provides comprehensive financial planning and investment advisory services.
Advisory Services
Circle Wealth Advisors Private Limited offers guidance using direct plans and non-commission earning products, ensuring unbiased advice in the client’s best interest. For these services, clients are charged a fee as per the agreed terms.
Investment Policy
Circle Wealth Advisors, its partners, and affiliates may invest in a variety of financial products and asset classes based on their investment objectives, which include but are not limited to, liquidity needs, asset allocation, risk tolerance, and time horizon.
Most Important Terms & Conditions (MITC) for Investment Advisers
Reference: Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/19 dated February 17, 2025
The Investment Adviser (IA) shall only accept payments towards its fees for Investment Advisory Services and is not permiƩed to accept funds or securiƟes in its account on the client’s behalf.
The IA does not guarantee returns, accuracy, or risk-free investments. All advice is subject to market risks, and there is no assurance of any returns or profits.
Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the IA.
Investment advice, only related to securiƟes shall fall under the purview of SEBI. In case of any services offered by IA related to products/services not under the purview of SEBI, IA shall disclose to the client and take appropriate declaration and undertaking from the client that such products/services and the services of IA in respect of such products/services do not come under the regulatory purview of SEBI and that no recourse is available to the client with SEBI for grievances related to such products/services or services of IA in respect of such products/services
This agreement is for the investment advisory services provided by the IA and IA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client without his/her/its specific and positive consent on every trade. Thus, the client is advised not to permit IA to execute any trade on his/her/its behalf without explicit consent.
The fee charged by IA to the client will be subject to the maximum amount prescribed by SEBI/Investment Adviser Administration and Supervisory Body (IAASB) from time to time (applicable only for Individual and HUF Clients).
Note:The current fee limit under Fixed Fee mode is Rs 1,51,000/- per annum per family of client. Under Assets under Advice (AUA) mode, maximum fee limit is 2.5 per cent of AUA per annum per family of client.
The IA may change the fee mode at any time with the client’s consent; however, the maximum fee limit in such cases shall be the higher of the fee limit under the fixed fee mode or 2.5 per cent of AUA per annum per family of client.
The fee limits do not include statutory charges.
The fee limits apply only for investment advice related to securities under the purview of SEBI.
The fee limits do not apply to a non-individual client / accredited investor.
IA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is a maximum of one year. In case of premature termination of the IA services by the client or the IA, the client shall be entitled to seek refund of proportionate fees only for the unexpired period. However, IA is entitled to retain a maximum breakage fee of not greater than one-quarter of the fee.
Fees to IA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally, the client can make payments through Centralised Fee Collection Mechanism (CeFCoM), managed by BSE Limited (i.e. currently recognised by IAASB).
The IA is expected to know the client’s financial details for providing services. Hence, the client is required to share the financial information (e.g. income, existing investments, liabilities, etc.) with the IA.
The IA is required to carry out the client’s risk profiling and suitability analysis before providing services and thereafter on an ongoing basis. The services provided will be in line with the assessed risk profile. IA shall also communicate the assessed risk profile to the client.
As part of conflict of interest management, the client or the client’s family members will not be provided any distribution services by IA or any of its group enemity/ family members. IA shall, wherever available, advise direct plans (non-commission-based) of products only. The IA shall endeavour to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
For any grievances,
Step 1: The client should first contact the IA using the details on its website or the following contact details:
saurabh@circlewealthadvisors.com / compliance@circlewealthadvisors.comStep 2: If the resolution provided by IA is unsaƟsfactory, the client can lodge grievances
through SEBI’s SCORES plaƞorm at www.scores.sebi.gov.inStep 3: If the client remains dissatisfied with the outcome of the SCORES complaint, the client may consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in
The SEBI registration, enlistment with IAASB, and NISM certifications do not guarantee the performance of IA or assure returns to the client.
Clients must keep contact details, including email ID and mobile number (s), updated with the IA at all times.
The IA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account, Demat Account and Bank Account. Never share such information with anyone, including IA.
