Regulatory Disclosures

Mandatory Disclosure by SEBI

• "Investments in securities market are subject to market risks. Read all the related documents carefully before investing."
• "Registration granted by SEBI, membership of BSEI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors."
• "We cannot promise or guarantee of assured risk-free return to the investors. We cannot imply any assured returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns or any other nomenclature that gives the impression to the client that the investment advice/recommendation of research report is risk-free and/or not susceptible to market risks and/or that it can generate returns with any level of assurance."

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Investment Adviser Disclosures

Disciplinary History

Information as required by Regulation 18(1)

No action has been taken against the IA by any regulator.

Terms and conditions on which advisory services are offered

Information as required by Regulation 18(1)

The ‘Investment Advisory Agreement’ will be duly signed and executed with the client, outlining the agreement (terms and conditions) between IA and its client, including the investment advisory services provided by IA, also incorporating the terms and conditions specified by the SEBI.

Further, the Most Important Terms and Conditions (MITC) forming part of the Investment Advisory Agreement, is published here for reference and perusal.

Most Important Terms and Conditions (MITC)

In accordance to SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/19 dt. February 17, 2025 and further updated by SEBI Circular No. SEBI/HO/MIRSD/ MIRSD-PoD/P/CIR/2025/48 dt. April 2, 2025.

1. The Investment Adviser (IA) shall only accept payments towards its fees for Investment Advisory Services and is not permitted to accept funds or securities in its account on the client’s behalf.
2. 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.
3. 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.
4. Investment advice, only related to securities 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 make disclosure 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 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.
5. 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.
6. The fee charged by IA to the client will be subject to the maximum of amount prescribed by SEBI/Investment Adviser Administration and Supervisory Body (IAASB) from time to time (applicable only for Individual and HUF Clients).

   Note:

   (i) 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.

   (ii) 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 higher of fee limit under the fixed fee mode or 2.5 per cent of AUA per annum per family of client.

   (iii) The fee limits do not include statutory charges.

   (iv) The fee limits apply only for investment advice related to securities under purview of SEBI.

   (v) The fee limits do not apply to a non-individual client / accredited investor.

7. IA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is maximum one year. In case of pre- mature termination of the IA services by the client or the IA, the client shall be entitled to seek refund of proportionate fees only for unexpired period. However, IA is entitled to retain a maximum breakage fee of not greater than one-quarter fee.

   Note: These fee related provisions do not apply to a non-individual client / accredited investor.

8. 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 Centralized Fee Collection Mechanism (CeFCoM), managed by BSE Limited (i.e. currently recognized IAASB).
9. 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.
10. 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.
11. 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 entity. IA shall, wherever available, advice direct plans (non-commission based) of products only.

    The IA shall endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.

12. For any grievances,

    Step 1: The client should first contact the IA using the details on its website or following contact details:

    Details of designation	Contact person Name	Address	Mobile	Email	Working hours
    Compliance Officer	R Ganesh	Regd. Off. (*)	+91 6381593332	[email protected]	10 AM to 6 PM
    Principal Officer	Sridevi V	Regd. Off. (*)	+91 9841428055	[email protected]	10 AM to 6 PM

    (*) Regd. Off. No.7/13, Ground Floor, Baktavatsalam Nagar, 4th Street, Adyar, Chennai – 600020

    Step 2 : If the resolution provided by IA is unsatisfactory, the client can lodge grievances through SEBI’s SCORES platform at www.scores.sebi.gov.in

    Step 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

13. The SEBI registration, enlistment with IAASB, and NISM certification do not guarantee the performance of IA or assure returns to the client.
14. Clients are required to keep contact details, including email id and mobile number/s updated with the IA at all times.
15. 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.

Other Information

Information as required by Regulation 18(1)

Ploutus Asset Services LLP is also registered with AMFI as a Mutual Fund Distributor having ARN 272069. The said distribution services are provided through Distribution Services Division – a separately identifiable department or division (SIDD).

Accordingly, the Investment advisory services are provided through Investment Advisory Division – another SIDD.

Information as required by Para 2(iii)(e) of SEBI Guidelines Circular No. SEBI/HO/MIRSD/ MIRSD-PoD-1/P/CIR/2025/003 dated January 08, 2025

Any services or activities undertaken by the IA, in relation to any other business or service (other than investment advisory), shall be outside the regulatory purview of SEBI, and no complaints in respect thereof may be raised with SEBI.

Holdings or Positions

Information as required by Regulation 18(4)

The IA, the Principal Officer and the Persons associated with investment advice (PAIA) may have holding or position, in the financial products or securities which are subject matter of advice.

The IA, the Principal Officer and the PAIA for their own individual / proprietary purposes may invest / divest in various securities / investments, from time to time at their own discretion. Such proprietary investment transactions may at times be contrary to the investment advice.

Conflict of Interest

Information as required by Regulation 18(5)

The IA does not have any connection to or association with any issuer of products / securities. Accordingly, there are no actual or potential conflicts of interest. Also nothing compromises the objectivity or independence in carrying on the investment advisory services.

Ploutus Asset Services LLP may offer tools and utilities as part of their website, services like investment advisory, distribution, and other services, through SIDD, each duly regulated and operated, as applicable, under different regulations, authorities and compliance requirements.

Accordingly, we ensure that:

1. Arms-length relationship is maintained with IA services.
2. Clear segregation is maintained with IA services, in the manner prescribed under IA Regulations.
3. Any conflict of interest of IA services with other activities, are disclosed to you. We ensure that, directly or through our group, we shall not provide distribution services to you, during the validity of the Agreement. In case you are receiving distribution services from us, directly or through our group, we shall not provide investment advisory services to you.

Products features

Information as required by Regulation 18(6) and 18(7)

The Client is requested to go through the key features of the products or securities, particularly track record, and warnings, disclaimers and other relevant information before investing, as and when advised by the IA.

Such details about the products or securities may also be available on www.sebi.gov.in or www.nseindia.com or www.bseindia.com.

Non-SEBI Products or Services

Information as required by Regulation 18(8)

In case of advisory services in respect of products or services which are outside the purview of SEBI — such products or services and related advisory services in respect of such products or services shall be outside the regulatory purview of SEBI and no recourse from SEBI shall be available to such clients for any grievance arising therefrom.

Use of AI tools

Information as required by Regulation 18(9)

The Investment Adviser uses certain third-party technology tools, including generative AI-based platforms, for research support, information summarisation, drafting assistance, and idea generation. The use of such tools is limited and assistive in nature and is subject to the following safeguards:

– AI tools are not used for automated, discretionary, or unsupervised investment decision-making.

– All investment advice is reviewed, validated, and finalised by the Investment Adviser based on professional judgment, client suitability, and regulatory requirements.

– AI tools do not directly interact with clients and do not provide advice independently.

– Client-specific advice is not generated solely by AI systems.

– Confidential client information is not knowingly uploaded to AI platforms in a manner that compromises data privacy or confidentiality.

The Investment Adviser remains fully responsible and accountable for the investment advice provided to clients, irrespective of the use of any AI or technology tools.

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Disclosure of Services and Compensation Structure

Ploutus Asset Services LLP offers both Investment Advisory and Distribution (Wealth Management) services. In accordance with applicable SEBI regulations, these two functions are strictly segregated at the client level, ensuring that no client simultaneously avails both services from the firm.

• Investment Advisory Clients: Clients engaging us for Investment Advisory services are charged a transparent advisory fee. For such engagements, Ploutus Asset Services LLP does not accept any commissions, distribution income, or other compensation from product manufacturers, thereby ensuring complete independence and absence of conflict of interest.
• Wealth Management / Distribution Clients: Clients availing Distribution services may invest in financial products through us. In such cases, the firm may receive commissions from product manufacturers and/or referral fees from other distributors. All such commissions and compensation arrangements are disclosed to the client prior to engagement, enabling fully informed decision-making.
• Indicative Commission Structure: The table set out below provides an indicative commission structure across product categories. This disclosure is made on a best-efforts basis and is reviewed and updated periodically. Pursuant to SEBI Circular No. SEBI/IMD/CIR No. 4/168230/09, details of commissions that may be earned by the Company from various Mutual Funds and Asset Management Companies are disclosed herein for the benefit of clients and prospective investors.
• Other Products and Services: The Company may, from time to time, offer additional products or services that are not specifically covered within this disclosure. Clients are encouraged to contact us directly for further details regarding such offerings, including the associated compensation structures, terms of engagement, and any applicable disclosures.

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Disclosure on Mutual Fund Commissions

In compliance with the SEBI circular dated 30/06/2009 bearing no. SEBI/IMD/Cir No.4/168230/09, please find below the commissions received by the Distribution Division of Ploutus Asset Services LLP from various AMCs whose schemes are being distributed.

Mutual Fund Distribution — Commission Disclosure

Ploutus Asset Services LLP is an AMFI-Certified Mutual Fund Distributor. As a distributor, we are compensated through brokerage paid directly by the Asset Management Companies (AMCs), based on the investments made by our clients. This brokerage forms part of the scheme's Total Expense Ratio (TER) — the all-inclusive percentage of expenses that the mutual fund charges to manage and operate the scheme.

We do not levy any separate or additional charges on our clients for distribution services. Our compensation is entirely embedded within the TER and is paid to us by the mutual fund house.

Understanding Your Returns

The returns reflected in your mutual fund statements are net returns — meaning all applicable expenses, including our distribution brokerage, fund management fees, and operational costs, have already been deducted before the return is calculated and displayed.

Illustration: If your investment shows a 12% annualised return over the past three years, this represents the actual return realised in your hands. All underlying expenses have been accounted for prior to this calculation.

In simple terms — what you see on your statement is what you earn.

We believe that mutual fund expenses are among the most transparent and easy-to-understand cost structures available across financial products today, and we remain committed to upholding this transparency in every client engagement.

Indicative Commission Structure — Mutual Funds

Note: The commission rates indicated above are general in nature, reflect prevailing market practices across leading Asset Management Companies, and are subject to periodic revision. Actual rates may vary across individual schemes, AMC arrangements, and over time. This disclosure is provided on a best-efforts basis and is not exhaustive. Clients are encouraged to contact us for scheme-specific or current details.