Portfolio Management Service Disclosure Document Dynamic Equities Private Limited "Technopolis" 14 th Floor, Plot No. BP4 Sector V, Salt Lake, Kolkata 700091 Phone: (033) 300 10000 Fax: (033) 300 10000 E-mail: compliance@dynamiccares.com
Key information The Document has been filed with the Securities and Exchange Board of India along with the certificate in the prescribed format in terms of Regulation 14 of the SEBI (Portfolio Managers) Regulations, 1993. The purpose of this Document is to provide essential information about the portfolio services in a manner to assist and enable the investors in making informed decision for engaging us as a Portfolio Manager. The necessary information about us as Portfolio Manager required by an investor before investing is disclosed in this Disclosure Document. You are advised to read this document and retain this document for future reference. The name, phone number, email address of the Principal Officer is as follows: Name of Principal Officer : Ms. Dolly Dhavle Phone No: 033 30010000 (Extn.1056) E- mail: dollyd@dynamiccares.com
JAIN & CO. Chartered Accountants TO WHOM IT MAY CONCERN This is to certify that the contents of the Disclosure Document in respect of Portfolio Management Services, as annexed, provided by M/s. Dynamic Equities Private Limited having its registered office at Technopolis, 14th Floor, Plot No. BP4, Sector V, Saltlake, Kolkata-700091, have been checked and verified by us on the basis of the information and explanations as provided as well as the relevant documents produced. Accordingly, we hereby confirm that the disclosure made in such Document are true, fair and adequate as to the requirements of Securities and Exchange Board of India (Portfolio Managers) Regulations,1993 to enable the investors to make a well informed decision. For Jain & Co. Chartered Accountants P. K. Jain Partner Date: August 04,2015 (Membership No. 52018) Place: Kolkata
FORM C Securities and Exchange Board of India (Portfolio Managers) Regulations,1993 [Regulation 14] Name of the Portfolio Manager: Dynamic Equities Private Limited Address: Technopolis Building, 14 th Floor, Plot No. BP 4, Sector V, Salt Lake, Kolkata: 700091 Telephone No: (033) 40099400 Fax No: (033) 30010000 E-Mail- compliance@dynamiclevels.com We confirm that: i) The Disclosure Document forwarded to the Board is in accordance with the SEBI (Portfolio Managers) Regulations, 1993 and the guidelines and directives issued by the Board from time to time; ii) The disclosures made in the document are true, fair and adequate to enable the investors to make a well informed decision regarding entrusting the management of the portfolio to us / investment in the Portfolio Management. iii) The Disclosure Document has been duly certified by an independent Chartered Accountant. Name of the Chartered Accountant- Mr. Pradeep Kumar Jain Address- P-21/22 Radha Bazar Street, Kolkata-700001 Phone No.- (033) 2426541 Registration No. 52018 Date: August 04, 2015 Dolly Dhavle Principal Officer Technopolis Building, 14 th Floor Plot No-BP4, Sector V, Saltlake Kolkata-700091
TABLE OF CONTENT Item No. Particulars Page No. 1. Disclaimer 4 2. Definitions 4-5 3. Description 5-8 4. Penalties, Pending litigation or proceedings etc. 8 5. Services Offered 9-11 6. Risk Factors 11-12 7. Client Representation 12-13 8. Related Party Disclosure 13-14 9. Financial Performance of the Portfolio Manager 14-15 10. Portfolio Management Performance of the Portfolio Manager 15 11. Nature of Expenses 16 12. Taxation 16-17 13. Accounting Policies 17-18 14. Reporting to the Client 18-19 15. Client Services 19-22 3
1) Disclaimer This Document has been prepared in accordance with the Securities and Exchange Board of India (Portfolio Managers) Regulations, 1993 and filed with Securities and Exchange Board of India (SEBI). This Document has neither been approved /disapproved by SEBI nor has SEBI certified the accuracy or adequacy of the contents of the Document. 2) Definitions In this Disclosure Document, unless the context otherwise requires the following expressions shall have meaning assigned to them hereunder respectively: (a) "Act" means the Securities and Exchange Board of India Act, 1992. (b) "Client" means any person who registers with the Portfolio Manager for availing Portfolio Management Service. (c) "Financial Year" means the year starting from 1 st April and ending on 31 st March of the following year. (d) "Funds" means the monies managed by the Portfolio Manager on behalf of the Client pursuant to this agreement and includes the monies mentioned in the application, any further monies placed by the Client with the Portfolio Manager for being managed pursuant to this agreement, the proceeds of the sale or other realizations of the Portfolio and interest or other monies arising from the assets, so long as the same is managed by the Portfolio Manager. (e) "Portfolio" means the total holdings of all investments, securities, and funds belonging to the client. (f) "Portfolio Manager" means Dynamic Equities Private Limited, a company incorporated under the Companies Act, 1956 and having its registered office at Technopolis Building, 14 th Floor, Plot No. BP4, Sector-V, Salt Lake, Kolkata- 700 091. (g) "Regulation" means the Securities and Exchange Board of India (Portfolio Managers) Regulations, 1993. 4
(h) "Rules" means the Securities and Exchange Board of India (Portfolio Managers) Rules, 1992. (i) "SEBI" means the Securities and Exchange Board of India. Words and expressions used in this Disclosure Document and not expressly defined shall be interpreted according to their general meaning and usage. 3) Description (i) History, Present Business and Background of the Portfolio Manager Dynamic Equities Private Limited was incorporated as a company on 16 th August 1999 by the Registrar of Companies, West Bengal, with its registered office at Gagandeep 1 st Floor, 50B Gariahat Road, Kolkata 700019. Shri Shailesh Saraf and Shri Shridhar Bhuwalka are the present promoters of the company. The company was formed with a vision to become a respected financial service provider in terms of both profitability and geographical spread. Dynamic EquitiesPrivate Limited Organizational Membership Exchange National Stock Exchange Limited ( NSE ) Bombay Stock Exchange Limited( BSE) MCX-Stock Exchange Limited( MCX-SX ) National Securities Depository Limited (NSDL) Central Depository Services (India) Limited (CDSL) Investment Advisory Services Segment Registration Nos. Registration Date Status CASH INB231071839 09-Dec-1999 Trading Member F&O INF231071839 20- Jun- 2000 Trading Member F&O INF231071839 05-Jul- 2002 Self Clearing Member CURRENCY INE231071839 16-Sep-2008 Trading cum Clearing Member CASH INB011071835 23-Dec-2002 Trading Member CURRENCY 0989 06-Feb- 2014 Trading Member CASH INB261071832 22-Jan-2013 Self Clearing Member F&O INF261071832 22-Jan-2013 Trading Member CURRENCY INE261071839 30-Sep-2008 Trading Member Depository Depository Investment Advisory IN-DP-NSDL- 161-2000 IN-DP-CDSL- 192-2002 14 Sep 2000 Depository Participant 01 Oct 2002 Depository Participant - INA300002022 July 28, 2014 5
On 16 August 2006, the corporate / registered office of the Company was shifted to Technopolis - 14 th Floor, Plot No. BP 4, Sector V, Salt Lake, Kolkata 700 091 for superior infrastructural facilities. Presently, the Applicant Company is providing financial services in the following areas: 1. Stock Broking Activity in Capital and Derivatives Market in NSE,BSE and MCX-SX. The applicant company has 27 (Twenty Seven) numbers of registered sub brokers, and 13 (Thirteen) Authorised Person 2. Dynamic is also providing Research to investors/public at large, through its website www.dynamiclevels.com 3. Jobbing and Arbitrage in Securities Market, Currency Derivatives and Commodities Market through its associate company. 4. Portfolio Management Services: The applicant company also provides Discretionary Portfolio Management Service through its separate PMS department. 5. Investment Adviser: The applicant company is also registerd as Investment Adviser Our Core Strengths: a) It has an extensively researched strategy in place, which has been developed after almost 9 years of rigorous study and analysis. b) It has infrastructure and facilities in place, which include sufficient office space, terminals, research software, risk management tools and timely backup measures. c) Attracting highest quality individuals to work with us and providing world-class corporate training to our employees. d) Banking with the best names in the industry like HDFC Bank, State Bank of India, ICICI Bank, Axis Bank. (ii) Promoters of Portfolio Manager, directors and their background Shri Shailesh Saraf and Shri Shridhar Bhuwalka are the present promoters and Directors of Dynamic Equities Private Limited. Mr. Shailesh Saraf, Managing Director and Mr. Shridhar Bhuwalka, Director jointly hold 100% of share capital of the company. 6
Shri Shailesh Saraf, B.Com (Hons.) from University of Calcutta, is Managing Director and Co- promoter of the Portfolio Manager. He is presently heading the research team of Dynamic Equities Private Limited. He has 23 years of experience in the securities market especially in areas related to capital & derivatives market operations, trading, research and management. Shri Shridhar Bhuwalka is B.Com (Hons.) from University of Calcutta, is a Director of the Portfolio Manager. He has 7.5 years of post graduation experience in securities market. (iii) Top 10 Group companies/firms Name Dynamic Commodities Private Limited Activities Commodity derivatives Trading and broking services. (iv) Details of the services being offered: Discretionary Portfolio Management Services Presently, the Portfolio Manager will provide only discretionary portfolio management services. Under such service, the choice as well as the timings of the investments decisions rest solely with the Portfolio Manager. In other words, the Portfolio Manager shall have sole and absolute discretion to invest Client's funds at any time as he deems fit as per the executed agreement. The Portfolio Manager's decision(taken in good faith) in deployment of the Client's fund is absolute and final and cannot be called in question or be open to review at any time during the currency of the agreement or at any time thereafter, except on the ground of malafide, fraud, conflict of interest or gross negligence. Provided however, that the funds herein shall not be in any manner be used for any such transactions or instruments as may be expressly prohibited by SEBI or RBI or other regulatory bodies from time to time. The Portfolio Manager shall exercise its power and be subject to obligations strictly in accordance with the Act, Rules and Regulations made there under. 7
The Client may, under these services, authorize or restrict the Portfolio Manager to invest the Client's Portfolio in specific financial instruments or securities or a mix of specific instruments or securities. The Portfolio Manager will send periodical statements to the clients. 4) Penalties, pending litigation or proceedings - Sr. Particulars Remarks No. (i) All cases of penalties imposed by the Board or None the directions issued by the Board under the Act or Rules or Regulations made there under. (ii) The nature of the penalty/direction. None (iii) Penalties imposed for any economic offence and/ or for violation of any securities laws None (iv) Any pending material litigation/legal None proceedings against the Portfolio Manager / key personnel with separate disclosure regarding pending criminal cases, if any (v) Any deficiency in the systems and operations of None the Portfolio Manager observed by the Board or any regulatory agency (vi) Any enquiry/ adjudication proceedings initiated by the Board against the Portfolio Manager or its directors, principal officer or employee or any person directly or indirectly connected with the Portfolio Manager or its directors, principal officer or employee, under the Act or Rules or Regulations made thereunder None 8
5) Services Offered by the Portfolio Manager: (a) Investment Strategy Presently we will provide only discretionary portfolio management services whereby trading in shares in cash market will be done. The client's funds will be managed by a team of experts comprising of strategists, technical analysts, quantitative analysts, etc. Our trading will be in accordance with a well devised research based strategy that seeks to make money consistently. It will seek to protect client s capital by using stringent money management techniques and risk management controls. Trend following, money management, handling emotions of greed and fear prevalent in the market, knowledge of global and local events, trends in global market have all been factored into the philosophy behind our trading strategy.research is based on use of the following two techniques: A) Technical Research: The technical analysis team focuses on determining trend changes over the short and long term and weighs the probability of that trend in decision-making. Statistical models or mathematical models are used to make buy or sell decision. The value of the exposure in the futures market will not exceed the value of the underlying portfolio at any point of time. The key elements of Technical research are: a) Studies historical data of price, volume, open interest and volatility to gauge the underlying trend. b) Determines the probability of that trend sustaining. c) Determine the entry and exit points based on such analysis. B) Equity Research: Key Elements of our approach to Fundamental Research are: Bottom-up stock selection In-depth, independent fundamental research High-quality mid cap companies with sustainable competitive advantages Disciplined valuation approach applying multiple valuation measures 9
The fundamental research will be based on study of the following 7 factors of the stock: 1. Price and Performance 2. Products and Services 3. People (Shareholding Pattern) 4. Philanthropy 5. Profitability 6. Peer Comparison 7. Prospects Investments will not be made in associated / group companies of the Portfolio Manager. Description of the Product Minimum initial investment amount in the product is Rs. 25 Lacs, We invest primarily in shares in cash Market based on Fundamental AND technical Research. Also we may invest in Derivatives to an extent of 10%- 20 %approx based on the opportunity as per the regulation. Our Strategy: It is based on our Seven Fundamental Principles (7Ps) which are as follows: 1. Price & Performance Price mainly refers to technical levels of the movement of the stock while performance falls into the category of fundamentals. A combination of both technical and fundamental is taken into consideration. 2. Products and Services Company s products and services (portfolio) that it offers to cater to the needs of the customers. This also categories the company in which sector it is operating, new products that is soon to be launched (If any) etc. 3. Profitability How the company s financials has been over a period of time. This analysis is done on a Quarterly basis. The highest weightage is given to the PAT of the company. 4. Peer Comparison A head to head comparison amongst the companies which belong to the same business line. Here the focus of the study is on their financials. 10
5. People (share holding pattern) The share holding pattern of the Company is studied to identify the owners of the company over a period of time. All public holding which is more than 1 percent is also identified. 6. Philanthropy The company s contribution to the society ie, the Corporate Social Responsibility. Here we see the company s sustainable developmental activities for the society in which it operates. 7. Prospects The SWOT analysis of the company is done. How the industry has been performing and what are the challenges before the company and industry in the future. The investment will be for a period of 3 to 5 weeks and the calls are strictly monitored with predefined stop. 6) Risk factors i. Investments in securities are subject to market risk and there is no assurance or guarantee that the objectives of the investments will be achieved. ii. The past performance of Dynamic Equities Private Limited does not indicate its future performance. Clients are not being offered any guaranteed returns. iii. Risk arising from the Investment objective, investment strategy and asset allocation: The securities market is, apart from other factors, dependant on performance of various industries, corporate, economy as a whole, the economic policies of the Government of India and particularly economic reforms, RBI s monetary and credit policies, the extent of liquidity prevailing in the system etc. Indian market, being integrated with global economy, NIFTY performance is also dependant to a large extent upon global indices, global economic performance and other global factors, etc. The performance in the capital market may be adversely affected by the performance of individual companies, changes in industry specific factors and other micro and macro economic factors and Global economy. There is no guaranteed return to client. iv. Investment in securities, whether on the basis of fundamental analysis or technical analysis or otherwise, is subject to market risks which include price 11
fluctuations, impact cost, basis risk etc. The Portfolio Manager does not assure or guarantee that the objectives of any of the model portfolios will be achieved. The investments may not be suitable to all the investors. v. Investments in equity may be adversely affected by the performance of companies, changes in the economy, government policy, the market place, credit ratings and industry specific factors. vi. Risk arising due to non diversification: Under the service offered by the Portfolio Manager no investment will be made in Debt market or in Government securities. Hence there is risk due to non diversification. a. The name of the scheme/service does not in any manner indicate its prospects or returns. b. The investments in securities may be subject to interest rate risk, liquidity risk, credit risk and reinvestment risk. Liquidity in these investments may be affected by trading volumes, settlement periods and transfer procedures. c. The performance of the Portfolio Manager may be affected by changes in Government policies, general levels of interest rate and risks associated with trading volumes, liquidity and settlement systems in equity markets. d. The inability to sell securities held in the Clients portfolio due to extraneous factors that may hinder liquidity, would result, at times, in potential losses to the Client, in case of subsequent decline in the value of securities held in the Clients portfolio. e. The Portfolio Manager has a track Record of providing Portfolio Management services with effect from December, 2013. 7) Client Representation: (i) Category of Clients No. of Clients Funds managed (Rs.) Discretionary/ Non Discretionary (if available) Associates /group companies Last 3 years Nil Nil N.A Others (last 3 years) 4 Rs. 1.13 Cr. Discretionary Total 4 Rs. 1.13 Cr. Discretionary 12
(ii) Disclosure in respect of transactions with related parties as per the standards specified by the Institute of Chartered Accountants of India. 8. Related Party Disclosures for the year ended 31/03/2015 Related party disclosures, as required by the Accounting Standard (AS - 18), are given below: a) Name of related parties and description of relationship : 1) Subsidiary - Dynamic Commodities Private Limited- 77.78% Subsidiary Company - Mr. Shailesh Saraf Managing Director 2) Key Management Personnel - Mr. Shridhar Bhuwalka Director 3) Enterprises over which Key Management Personnel are able to exercise significant influence - Dynamic Credit Finance Pvt. Ltd. (b) The following are the related parties with whom no transactions were carried out during the year: Dynamic Insurance Brokers Pvt. Ltd. Chandra Vyapaar Pvt. Ltd. Shailesh Real Estate Private Limited Bhuwalka & Co. Pvt. Ltd. Transactions with Related Parties Nature of Transaction Subsidiary Company Key Management Personnel Others Total - - - - Loans Taken ( - ) ( - ) (9,500,000) (9,500,000) Loans Repaid - - 9504438 9504438 ( - ) ( - ) - - Service Charges Paid 48,00,000 - - 4,800,000 (6,000,000) ( - ) ( - ) (6,000,000) 13
- - 18279 31,562 Interest Expense ( - ) ( - ) (4438) (4438) - - - - Proposed Dividend ( - ) (500000) ( - ) (500000) ( - ) (5,00,000) ( - ) (5,00,000) Figures within the brackets relate to the previous year Disclosure in respect of transactions with related parties pertaining to Portfolio Management Services The Portfolio manager is a member of the National Stock Exchange of India Ltd. (NSE), Bombay Stock Exchange (BSE). The Portfolio manager is also a registered depository with NSDL and CDSL. For the purpose of executing transactions of purchase and sale of securities the Portfolio Manager would transact through the membership held by the Portfolio Manager in NSE and BSE as mentioned above. Brokerage will be charged for such transactions as per clause 11. The Portfolio Manager will use the Depository Participant services of Portfolio Manager itself and Depository charges will be charged as per clause 11. 9) The Financial Performance of the Portfolio Manager The following represents the summarized financial performance of the Portfolio Manager as per the audited financial statements. Balance Sheet EQUITIES & LIABILITIES As at March 31, 2013 14 As at March 31, 2014 (Amount in Rupees) As at March 31, 2015 Shareholder's Fund 319,029,458 319,195,868 319,503,464 Loans 0 0 0 Deferred Tax Liability 948,000 872,000 337,300 Current Liabilities & Provision 81,390,496 52,420,538 90,263,530 Total 401,367,954 372,488,406 410,104,294 ASSETS Fixed Assets 11,426,264 9,675,366 6,871,103 Deposits 65,145,577 41,255,500 38,912,500 Investments 246,518,290 264,808,529 271,623,847 Current Assets 78,277,823 56749011 92,696,844 Total 401,367,954 372,488,406 410,104,294
(Amount in Rupees) Profit & Loss Account 10) Portfolio Management performance of the Portfolio Manager as on 31 st July 2015 a. Individual Client Investment Summary For the year ended March 31, 2013 March 31, 2014 March 31, 2015 Total Income 153,306,394 107,267,699 118,489,981 Total Expenses 132,448,352 103,820,952 115,197,487 Profit Before Tax 20,858,042 3,446,747 3,292,494 Provision for Taxes 4,635,526 2,695,362 1,499,350 Profit after Tax 16,222,516 1,793,144 751,385 PMS CLIENT CODE PMS0002 PMS0003 PMS0004 PMS0005 Since a/c opening date 12/06/14-31/07/15 27/11/14-31/07/15 18/03/15-31/07/15 12/12/14-31/07/15 Starting Corpus 25,00,000.00 25,00,000.00 25,00,000.00 25,00,000.00 Further Contribution 0 0 0 19,00,000.00 Withdrawal 454,341.88 0 0 14,01,300.00 Net Contribution 20,45,658.12 25,00,000.00 25,00,000.00 29,98,700.00 Current Value 26,28,838.54 27,01,284.48 25,28,836.65 32,76,889.68 Absolute Profit(+)/Loss(-) 5,83,180.42 2,02,259.48 28836.13 2,78,189.70 S. No 1 2 Absolute Return % 28.51 8.09 0.64 9.28 XIRR Return % 28.51 8.09 0.64 9.28 b. Relative Performance Report for Individual client PMS CLIENT CODE PMS0002 PMS0003 PMS0004 PMS0005 S&P CNX Nifty as on a/c opening date S&P CNX Nifty as on 31/07/2015 3 AUM as on a/c opening date 7649.9 as on 12/06/2014 8494.2 as on 27/11/2014 8685.9 as on 18/03/2015 8224.1 as on 12/12/2014 8532.85 8,532.85 8,532.85 8532.85 25,00,000.00 as on 12/06/2014 25,00,000.00 as on 27/11/2014 25,00,000.00 as on 18/03/2015 25,00,000.0 0 as on 12/12/2014 4 AUM as on 31/07/2015 26,28,838.54 27,01,284.48 25,28,835.85 32,76,889.7 0 5 Absolute Return % S&P CNX Nifty 11.34 0.46-3.03 4.91 6 Absolute Return % Portfolio 28.51 8.09 1.15 9.28 15
11) Nature of expenses: (i) Upfront fees: 1% (ii) Performance Based Management Fees: Hurdle Rate 10% of the invested amount Performance fees 20% Profit Sharing over the hurdle rate on High Watermarking Basis. Exit Fees Between0-6 months 2 %, 6-12 months 1% Management Fees 1.5% p.a to be levied quarterly Brokerage As Applicable at Actuals Depository Fees As Applicable at Actuals Service Tax, Security Transaction Tax & Other Statutory Levies As Applicable at Actuals (iii) Depository Charges (If applicable): Transaction charges Market Sale NSDL Mkt. Trxn. through CM-DEPL Rs.9/- for per ISIN Transaction charges Buy Nil A/c maintenance charges Per Annum For Individuals- Rs. 400/- For Corporates Rs. 900/- iv) Brokerage: \ @0.25% in case of delivery trades; @0.025% on turnover in case of square off trades and future contracts or as mutually agreed. Flat Rs. 25 on Option contracts per lot. The above amount is payable to the broker for transactions executed on Clients account. (v) Statutory and Incidental Expenses: Stamp Duty, Securities Transaction Tax, Service Tax and any other statutory charges would be levied separately as per the prevailing rates from time to time. 16
12) Taxation - i) General: In view of the individual nature of tax consequences, each Client is advised to consult his/her tax advisors with respect to the specific tax consequences to him/ her of participation in the portfolio management service. The Portfolio Manager shall not be responsible for assisting in or completing the fulfillment of the Client's tax obligation. ii) Tax Deduction at Source: If any tax is required to be withheld on account of any legislation, the Portfolio Manager shall be obliged to act in accordance with the regulatory requirements in this regard. Interest and dividends would be subject to tax as per the provisions of the Income Tax Act, 1961. iii) Securities Transaction Tax: As per Income Tax Act, 1961 any security which is transacted on any recognised Stock Exchange is subject to payment of Securities Transaction Tax (STT). The amount of STT charged against any transaction in respect to the Clients portfolio shall be debited to his account as an incidental expense. iv) Transaction in Futures & Options segment: In regard to amendment brought out in the provision of the Income Tax Act, 1961 in the Union Budget 2006-07, transactions in the Futures & Options segment, and the circular issued by the CBDT recognizing the BSE and NSE as Recognized Stock Exchange, the transaction in the F&O segment would be treated as business income, and would be taxed accordingly. 13) Accounting policies: The following accounting policy/ valuation will be applied for the portfolio investments of the Clients: I. Recognition of transactions: Transactions for purchase or sale of securities will be recognised as on the trade date and not as on the settlement date so that the effect of all investments traded during a financial year are recorded and reflected in the financial statements for that year. II. Derivatives Transactions: Unrealised gains and losses on open position will be calculated by mark to market method. III. Dividends, interests etc: Dividends on shares and units in mutual funds, interest on debt instruments, stock lending fees earned etc. shall be 17
accounted on accrual basis except interim dividends which would be accounted on receipt basis. IV. Separate accounts shall be maintained for each client and each investment V. Investments in Equities will be valued at the closing market prices of the Exchange (NSE or BSE as the case may be). VI. Investments in Equities, Mutual Funds and Debt instruments will be valued at the closing market prices of the exchange (BSE or NSE as the case may be) or the Repurchase Net Asset Value declared for the relevant scheme on the date of the report or any cut off date or market value of the debt instrument at the cut off date. Alternatively, the last available prices on the exchange or the most recent NAV will be reckoned. VII. Realized gains/losses will be calculated by applying the First in/ First out principle. For example, the earliest purchased quantity will be reckoned for the current/most recent sale at the respective prices at both points in time. VIII. Unrealised gains/losses are the difference between the current market value/navs and the historical cost of the securities. IX. Dividends on the shares and units in mutual funds, interest, stock lending fees earned etc, shall be accounted on receipt basis. The interest on debt instrument shall be accounted on accrual basis. X. The Portfolio Manager and the client can adopt any specific norm or methodology for valuation of investments or accounting the same as may be mutually agreed between them on a case specific basis. XI. The Client may contact the customer services official of the Portfolio Manager for the purpose of clarifying or elaborating on any of the above policy issues. 14. Reporting to the Clients: The following reports will be sent to the clients (i) Quarterly reporting of portfolio holdings/transactions, networth, ledgers, fees, corporate benefits etc 18
(ii) A copy of audited portfolio account to be issued to all the client annually. The Reports will mainly contain the following: (i) (ii) (iii) (iv) (v) The composition and the value of the portfolio, description of security, number of securities, value of each security held in the portfolio, cash balance and aggregate value of the portfolio as on the date of report. Transactions undertaken during the period of report including date of transaction and details of purchases and sales. Beneficial interest received during that period in respect of interest, dividend, bonus shares, rights shares and debentures. Expenses incurred in managing the portfolio of the client. Details of risk foreseen by the portfolio manager and the risk relating to the securities recommended by the portfolio manager for investment or disinvestment. 15) Clients services (i) Client relation officer who shall attend to the Client queries and complaints. Name: Ms. Dolly Dhavle Address: "Technopolis", 14 th Floor, Plot No. BP4 Sector-V, Salt Lake Kolkata 700091. Telephone:(033) 300 10000 E-mail: dolly@dynamiclevels.com, compliance@dynamiclevels.com (ii) Grievance Redressal and Dispute Settlement mechanism: Investor Grievance Re dressal Policy Objective: To have a Customer centric, compliant and timed grievance handling and redressal system leading to minimal recurrences. Scope: All complaints are received from the Client across the organisation to be dealt with care and attention. 19
Resolving client grievances/complaints give us the opportunity to review our processes and take necessary steps to prevent such recurrences. The aim is to respond to client complaints with efficiency, courtesy and fairness. Grievance/complaints can be received in the following way: 1. Through Email from the Client at compliance@dynamiclevels.com or at the email ID of employees of Dynamic. 2. Received from the Client over the phone (+91 33 40099400/ 30010000) by any of our employees 3. Through a written letter to The Compliance Officer Ms. Dolly Dhavle 4. Received through Regulators/Exchanges Manner of Handling Complaints/Grievances 1. All Complaints received are entered into the Complaint register (physical and soft copy) and indentified for which department the same is associated to. 2. Designated officer from the relevant department study the nature of the Complaint/grievance. 3. A call is given to the investor to understand the entire matter (if required) 4. Based on the nature of the Complaint/Grievance a detailed scrutiny and verification of clients records is carried out to reach to a valid conclusion. 5. If the value involved is high or matter is of grave concern then the Managing Director is also informed/involved 6. If required a meeting is arranged between all the related parties 7. After necessary clarifications, discussions and validations the matter is resolved/settled, with the clients. 8. After the matter is settled a letter to that effect is issued to the investor stating that the matter is settled and closed and acknowledgement obtained. 9. Necessary entry is made in the complaint register and reported to the Managing Director. 20
Escalation Matrix LEVEL 1 Executive Level All registered Complaints/Grievance at Executive Level, Expect a resolution from us within 3 working days. If you are not satisfied with the resolution provided by the Executives, kindly write to Compliance Officer @ dolly@dynamiclevels.com /compliance@dynamiclevels.com LEVEL 2 - Compliance Officer Ms. Dolly Dhavle You will receive a response from the Compliance Officer within 5 working days. If you are not satisfied with the resolution provided by the Compliance Officer, kindly write to the Managing Director LEVEL 3: Managing Director Mr. Shailesh Saraf You will receive a response from the Managing Director within 7 working days. Request for Arbitration In case the Client is not satisfied with the Resolution given by Dynamic, he/she can file for Arbitration at the Regional Arbitration Centre - Kolkata of relevant Exchanges. For details guidelines on the process of filing Arbitration, please visit the website of NSE, BSE, MCX SX. This is applicable if the complaint/grievance is related to trading/broking aspect. Registering the Complaint at Scores.gov.in In addition, client can submit his complaints/ grievances Online at SEBI s website www.scores.gov.in (SEBI Complaints Redress System). The Compliance Officer is responsible for handling all investor grievances primarily but in certain cases where the investor communicates directly with any particular department to which the matter is related, the concerned Department also resolves them directly. If the matter is of serious concern and if required, the Directors are also involved in the settlement. 21
Tracking of Pending/ unresoved Complaints: For letters received from Regulators/Exchange, reply is generally submitted within the deadline time as provided by the Regulator/Exchange. For all other source of Complaints reply is usually sent within 7 working days to the end client. In case the matter could not be closed within the stipulated time the same is escalated to the Managing Director for necessary action. Under any circumstance, the reply is definetly sent to the clients within 30 days of registration of the Complaint/Grievance. Internal Audit Internal Audit team conducts periodic audit for adhering to the above process of Grievance/Complaint handling mechanism and timed response to clients. Any adverse observations are to be reported by the Audit Team to the Compliance Officer and included in the Audit report. For Dynamic Equities Pvt. Ltd. For Dynamic Equities Pvt. Ltd. Shailesh Saraf Managing Director Shridhar Bhuwalka Director Date: August 04, 2015 Date: August 04, 2015 Place: Kolkata Place: Kolkata
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