True Beacon ‘TRUE BEACON INVESTMENT ADVISORS LLP Portotio Management Services ~ Disclosure Document This disclosure document ("isdosure Document’) has been filed withthe Securities and Exchange doar of india lang withthe cetfcate inthe specified format in terms of Regulation 22 of the Secures and Exchange Boar of India (Portfolio Managers) Regulations, 2020. ‘The purpose ofthe Disclosure Document i fo provide essen information bout the portfolio. sercesina mannerto asst and enable the investors making informed decisions for engaging ‘rue Beacon Investment Advgors LLP a a Portfolio Manager The necessary information about the Portfolio Manager requiredby an investor before investing is escosed in the Discosure Document. Investors should caretilly read the entire Disclosure Document before making 3 decision to aval portfoio management services from True Beacon Investment Advisors LP and should retain the Disclosure Document for future reference Detaiso the Portfolio Manager ae as follows Name ofthe Portfolio Manager: True Beacon Investment Advisors LP SEBI Registration Number Po00007353 Registered Office Address "The Marquis, 3" Flor, No. 19, Vital Mallya Road, Bengali, Karnataka 56000 naa Telephone number 1919663803202 Email adaress ‘mealth compliance@tcuebescon cm Website wir truebeacon.com Detalls ofthe Principal Officer designated by the Portfolio Manager are as follows Name ofthe Principal Officer: Mr. Saurabh Dhole ‘deress ‘The Marquis, 3° Floor, No. 19, Vital Mallya Road, Bengaluru, Kornatata 560001 Inala Telephone number +91 8067540000 E-mail address saurabh@tuebeacon som ‘This Disclosure Document dated 31 March 2023 “True Beacon, The Marqus, 3d Flor, No 19, Vital Malva Road, Bengaur, Karnataka, nda 50000" ‘ww rusbeacon com| in@truebescon com | +1 95-639.05202True Beacon DEFINITIONS AND INTERPRETATION. INTERPRETATION. DESCRIPTION. PPENALTIS, PENDING LITIGATION OR PROCEEDINGS, FNDINGS OF INSPECTION OR INVESTIGATIONS FOR WHICH ACTION MAY HAVE BEEN TAKEN OR INITIATED BY ANY veer REGULATORY AUTHORITY. a svn 10 6. SERVICES OFFERED snr tt 7. RISK FACTORS 3B 8. CLIENT REPRESENTATION se 92 9, DETAILS OF CONFLICT OF INTEREST RELATED TO SERVICES OFFERED BY RELATED PARTIES (OR GROUP COMPANIES OR ASSOCIATES sen 10, THE FINANCIAL PERFORMANCE OF THE PORTFOUO MANAGER BASED ON AUDITED FINANCIAL STATEMENTS AND IN TERMS OF PROCEDURE SPECIFIED BY SEBIFOR ASSESSING THE PERFORMANCE su ee 11, PORTFOLIO MANAGEMENT PERFORMANCE OF THE PORTFOLIO MANAGER FOR THE LAST THREE YEARS AND IN CASE OF DISCRETIONARY PORTFOUO MANAGER, DISCLOSURE OF PERFORMANCE INDICATORS CALCULATED USING “TIME WEIGHTED RATE OF RETURN” [METHOD IN TERMS OF REGULATION 22 OF THE PMS REGULATIONS... 2 132, AUDIT OBSERVATIONS OF THE PRECEDING THREE YEARS MI eonnnnsne 23 13, NATURE OF EXPENSES. 14, TAXATION. _ 35. ACCOUNTING POUCIES nes 16, INVESTORS SERVICES. 17, DETAILS OF INVESTMENTS IN THE SECURITIES OF RELATED PARTIES OF THE PORTFOLIO MANABER nnn 18, DETAILS OF THE DIVERSIFICATION POLICY OF THE PORTFOUO MANAGER... FORM Ce ANNERURE A. ANNERURE 2 ANNEXURE 3. ive Beacon, The Marquis, 3rd Floor, No 19, Vita Mala Road, Bengaluru, Karnataka, nla "360001 ww tuebeacon com| nto@iruabeacon com +91 96-630-08202Th 24 25 rue Beacon DISCLAIMER The particulars of this Disclosure Document have been prepare in accordance with the Securities and Exchange Board of ncla (Portolo Managers) Regulations, 2020 ("PMS Regulations") and fled with the Secures and Exchange Board of india (SEB). Ths Disclosure Document has nether been approved nor dsspproved by SEBI nor has SEBI ‘ertied the acuracy or adequacy ofthe content ofthis Disdosure Document. The porto ‘managers decison [taken n good fat) n deployment oftheChents' accounts absolute and final and cannot be ale in question or be open to review atime during the curency ofthe agreement or any tne thereafter except onthe ground of maafde, rau, conte of interest fF 08 negligence. The distribution ofthis document may be restricted or rohbited in certain jriscietions and accordingly, persons who come ints possesion ofthis document fare required to inform themselves about and to observe any such restrictions DEFINITIONS AND INTERPRETATION ‘associate’ shall have the meaning ascribed to the term under the PMS Regulations. “Applicable tas" means the laws ofthe Republi of Indi and includes rules and regulations Issued pursuant to and under such laws, including the PMS Regulations ‘Acereitation Agency’ means a subsidiary of a recognized stock exchange ora subsidiary of «2 depository or anyother entity as may be speified by the SEB from time to time. "neerdited Investor” means any person who has been granted 2 certificate by the accreditation agency who: {a} incase of an individual, Hinds undivided family, fay tus or Sole proprietorship has: {i annvalincome of teas INR 2 crores oF (i) net worth of at east NR 75 cots, out of which ne less than INR 3.75 crores isin the fom of nancial assets (i) annval income ofa least NR crore and minimum net worth oF NRS crores out of ‘which nat less than INR 2.5 crores inthe form of fancil assets (0) incase ofa body corporate has net worth ofa last INR SO crores, {6) incase ofa trust other than family tus, has net worth ofa least INR 50 coves {6) incase ofa partnership frm set up under the indian Partveshin Act, 1932, each partner independentiy meets the eligbiity criteria for accredtation: Provided that the central government andthe state governments of ina, developmental agencies setup under the aegis of the central government or te state governments of indi, funds set-up by the central government of the sate gevernments of India, qualified insiuiona buyers as defined under the SEB! (ssue of Capt and Disclosure Requirements) Regulations, 2038, Category I foreign portfolio investors, sovereign wealth funds and rmultiatera agencies and anyother ently a¢ maybe species by the SEB rom tine to tine, Shall deemed tobe an accredited investor and may not be required to obtain a cetieate of accrediation "ndulsory Services’ means the investment adulsory in terms of the PMS Regulations an shall include the responsibilty of advising onthe portfolio strategy Investment and divestment of “True Beacon, The Marq, 3d Fler, No. 1, Vital Mallya Road, Bengaluru, Kamaiks, India ‘360001 ‘wane trveboacon com | nfogituebeacon com | +91 86:536.03202True Beacon 26 a7 aa aaa aaa aas Ingidval Secures in the Clients’ Portfolio, for an agreed fee structure and fora period hecenafter described, eniey a the ents, tal egible categories of investors “Agreement” or “Portfolio Management Services Agreement” or "PMS Agreement” means the portfolio management agreement exacuted between the Fortfoko Manager and its Cents in accordance wth the PMS Regulations “Cent” or “Investor” means any person who enters into an Agreement for avaling the Portfolio Management Service offered by the Portfolio Manger. ‘Compliance Officer” means the afficer, not being the Princgal Officer appointed terms of Regulation 72(4) ofthe PMS Regulations or employe ofthe Portfolio Manager appointed in terms of Regulation 72K) ofthe PMS Regulations, who sha be responsible for monitoring the compliance of the Portfolio Manager withthe SEBI Act, 1992 rules and regulations, notation, gullies, instructions et, issued by SEI or the central government of ina an for edresal of Cents grevanees. “Discretionary Portfolio Management Services" or“Diseretlenary Services” means potfolo| management sevices rendered to the Cent by the Poroio Manager on the terms and ‘conditions contained inthe Agreement, where the Portfolio Wanager exercises any degree of discretion ia the investment or management ofthe Portfolio cr the Funds of the Client asthe ‘ase may be, Disclosure Document” of “Document means this dacumest prepared in accordance wit the PMS Regulations disclosing inter aia fotowing i) performance of the Portfolio Manage; {i portfolio risks (ithe quantum and manner ef pyinentof fees payable by a Clent (vy) dicosure in elation to related party transactions as well as details of cont of terest related to services offered by Related Parties or group companies oF associates of grOUp companies et. “Funds” means the monies managed by the Portfolio Manager on behalf of the cent pursuant to the PMS Agreement and includes the Investment amount mentioned in the ‘account opering frm, any monies placed by the Client with te Pertfoo Manager from time to time forthe purposes of being managed pursuant tothe PMS Agreement, the proceeds of the sale or other eazation ofthe Portoio an interes, dends and other monies arising {rom the Portfolio investments, so long asthe same is managed bythe Porto Manage. “GIFT” means Gujarat international Finance Tech Cy. “avn means indian Rupees. “Large Value Accredited lnvestc" means an accreted investor who has entered into an agreement with the portfolio manager fora minimum investment amount of INR 10 crores. Non-Disertionary Portfolio Management Services” or"Non-iscretonary Services” means partoio management services rendered tothe Cent by the 2otoio Manager cn the terms find conditions contained in the Agreement, where the Fortflio Manager ats on the Instructions received fom the Client with regard to investment or management of Portfolio “Tue Beacon, The Marqus, rd Flor, No 19, Vial Malya Road, Eenglur, Karnataka, nda 6000" ‘a ruebeacon com | nfotvebeacon com | +81 96630-02202True Beacon cor Funds ofthe Cent and will exercise no clceton 2st the investment or management of the Portfolio. 26 "artes" shall eer tothe Portfolio Manager and the Cllent collectively, and "Party shall relor tothe Portfolio Manager ad the Cheat severally 2.47 "PMS Regulations” means the Secures and Exchange Boar of Indl Portfolio Managers) Regulations, 2020, as amended, modified, restate, and/or eenactd from time to time. The term PMS Regulations shal aso deer o include al guidelines, directions, regulations, ules and notifications tesue by the government or any statutory regulatory authority or SEBI forthe operation and management of portfolio managers, or ny leslatin in regard thereto, if applicable to the Portfolio Manager Portfolio Manager” means True Seacon Investment Acvisors LLP, 2 limited liability partnership incorporated under the United Lablty Partnership Act, 2008, 2.19 “Portfolio” means the toal holdings of Secures and Funds managed by the Portfolo _Monageron behaf ofthe cient pursuant to the PMS Agreerent and includes any Securities and Funds mentioned inthe secount opening form, any further Secures ad Funds paced bythe Glen with the Portfolio Manager forthe purposes of bring managed pursuant to such Agreement, Secures o other ealsatios ofthe Portoio acquired bythe Portfolio Manager ‘hrounh investment of Funds and borus and rights shares on account of any corprate actions Inrespect of Secures forming part ofthe Portfolio, so long the same are managed by the Portfolio Manager pursuant tothe PMS Agreement 1220 "Principal officer” means an employee ofthe Portfolio Manager who has een designated 3s such by the Portfolio Manager andi responsible for) the decisions made by the Portfolio ‘Manager in terms ofthe management o administration of Patol of Secures and Funds ofthe lent; and il operations ofthe Potolo Manager. 2.21 "Related Parties” inrelation tothe Portfolio Manager shall mz: {a)a rector, partveror his late {b)a key managerial personnel or hi rlative {cl afi, inwhicha director, partner, manager o¢ his rete is9 partner {dha private company in which director, partner or marager or hs relative isa member ordirector (ela public company in which director, partner or manager isa director or holds along ‘th his elatves, more than two pe ent of ts pad-yp share capita (1) any body corporate whese board of directors, managing dtector oF manager is accustomed to actin accordance with the advice, directions or instructions of a Girecor, partner or manager: (e) any person on whose advice, directions or nstrutionsa drectr, partner or manager Is accustomed to at: Provided tht nothing in sub clus (ond (i) shal opp to the advice, cretion or instractons given in a profesional capacity, (6) anybody corporate whichis: (a) aholdng,subsisiary or an associate company ofthe portfolio manager “Tue Bescon, The Marque, 2d Flor No 19, Vital Malye Read, Gangalr, Kamala, nd 50000" ww ruebeacon com | nfo@ttvebeacon com | +91 9639-02202True Beacon an aa 32 33 {8) a subsidiary of a holding company to which tte portfolio manager is aso a subsiding, {c)an investing company or the venturer ofthe Porto Manager; Explanation —for the purpose of this clause, —inveting company or the venture fof a Portfolio Manager means a body corporate whose investment inthe portoio ‘manager would result inthe Portaio Manager beccming an associate of the body {i a relates partys defined under the applicable accounting standards ) such other person as may be spcted by SEB Provides tat, (0) any person or entity forming a pat ofthe promoter or promoter group of the listed enty; o [any person or any ent, holding equity shares: () of {went pr centormore; or (i) ten percent or more, with effect rom Apr 2, 2023; Inthe listed entty elther direct or on a benefcial intrest basis as provided ‘under section 89 ofthe Companies At, 2013, at any time, during the immediate preceding financial yea; shal be deemed tobe areled party “Sear means the Securities and Exchange Goard of nda established under sub-section (2) of Section 3 ofthe Secures and Exchange Board of Ina Act, 982, a amended from time to Secutiee” means secutty a8 defined in Section 2(h) ofthe Securities Contact Regulation) [Act 1956, provid that securities shal not incl any secures which the Portfolio Manager is protibited fram investing nor advising on unde the PMS Regulations or anyother aw for ‘the time being in Force. INTERPRETATION ‘Words and expressions used inthis dscosure document and not express defined shal be interpreted according other general meaning and sage. ‘The definitions are not exhaustive and have been included only forthe purpose of clay and hall in adaton, be interpreted according o thet general meaning at usage and shat nt ‘ary meaning asigned to them in PMS Regulations governing portfolio management ‘ilreferences to the masculine shall inlue the feminine ad all references, to the singular stall inclde the plural and vice versa DescRPTiON story, present business and background ofthe Portfolio Manager 4.41 True Bescon Investment Advisors LLP ("rue Beacon LP") is 2 limited lability partnership setup under the Limited Uablty Partnership Act, 2008 on October 22, 2018, bearing LLP Wentfication Number AAN-4560 ard having its egstered office at ‘he Marquis, "Hor, No. 19, Vita Mallya RoadBengaluru~560 001 “rue Beacon, The Marq, 3d Flr No 19, Vital Mabya Road, Gengair, Karnataka, In "50000" ‘wae ruebeacon com | nfogttuebeacon com | +91 96639-03202True Beacon 4.1.2. The objectne of True Beacon LLP i to vender fnandal and investment consultancy and procedural services as Portfolio Manages to prutently manage funds in various venues ike equity, debt, mutual fund units, government securities and such other financial instruments and securities in accordance withthe PMS Reguations. 4.13 Present, True Beacon LLP acts as an investment manager to True Beacon AF (Fund's Category il atemative investment fund (open ended) registered under the Secures and xchange Board of india [Stemative. Investment Funds) Reguations, 2012, bearing egistration number IN/AF3/18-20/070. The Fund has, most recently, launched its second scheme, True Beacon Scheme 2, which has 3 combination of sted equity and sovereign-backed debt asa lucrative ternative to traditional iavestment avenues, Further, The Beicon Invetient Advisors UP through it branch office located in Gujrat International Finance Tee City (GIFT) also the investment manage of Tue Beacon Global GIF's first operational Category IWF, registered withthe international Financial Seces Centres Authority. 42. Promoters ofthe Portfolio Manager, Partners and their bacground ii Richard Pattie and Mr. Saransh Maheshwari are the Designated Partners and Mr. Nthin Kamath, Mr Niki Kamath and Mr. Abhijeet Pal are partnersof True Beacon UP. Additionally, True Beacon LLP has also appointed Mr. Sawabh Bhushan asthe head of Pis/weath (a) Designated Partners and Partners: Master cf the Household of TRH The Me Richard Patle {Hors} Business Prince of Wales and The Duchess of Studies (2:]| ComwalUx from 2008 to 2018 Bournemouth |* Vice Charman, Standard. Chartered University Private Bank, UK from 2014 to 2018. 192, ‘+ CEO, REF Holdings, UAE from 2038 to '¢ msc _Detence and Strategic © Senior ‘disor, Standard. Chartered Studies Private Bank and Founder, Bright Str (Ostincton) -| Global Management Consutancy, UAE University of, from 2019 date Madras 2007 ‘Chartered | Advisory services inthe field of Transfer ‘Accountant |” Pig, Tax Restructuring, Dect and crAtevel2 | indirect Toxappiabilty. com (Hons) ‘Worked in Fund Accounting in ase management division for an alternative 2013. ic Saransh Maheshwari “True Beacon, The Marques Floor, No 19, Vital Malya Ros, Bengaluru, Karnataka, nda "560001 ww tuebeacon com | nfo@truebeacon com | 91 9-630-03202True Beacon investment fund managing Solar assets in North America of mit bilon dol Preparation of financial statements Including consoldation with accounting ‘uances ke hypothecated lquidated book va, sola renewable energy credits and interest ate swaps ee i. thin Kamath Higher Secondary ‘Work exerience of 15 years and above asa trader ‘ay Tracer from April 2000 t0 Apri Sub Broke of Reliance Money fom May 2006 to Fp 2010, ‘Managing Partner of Zrodha from Feb] 2010to March 2019, DDector in Zerocha Broking Lites {com Mach 2019 to Tl Date Director of Zerodhe. "commode Private ited from 2010 ti date Ni ik Kamath Senior Secondary ‘Work egerience of 10 years and above asa trader Independent Trader from 2008 0 2006 Sub Broker ofWay2weath fom 2008, 2010 Partner at Kamath Associates from Cofeunder of Zetodha from 2010 to March 2013 Direct in Zerodha Broking United feom Mach 2019 to Til Date Co-founder t True Beacon fom August 201910 Present i Abit Pal Mechanica Engineer wit] Peo Corfounder and’ Parner of Gruhas Poptech Ud where he leads and ‘manageste Investment team as wellas| the sourcing and evaluation of Investment opportunites Promoter of Puzolana Group where he acts as an advisor on Development and stratee Panning Business| True Beacon, The Margu, Sr Foo, No, 10, Vital Mala Road, Eongaluu, Karnataka, Inia ‘58000 ‘wa iruebeacon com | nfogttveboacon com | +8t 96439-03202True Beacon Punolans Group with an aim to be a leader in all product fares thatthe {) Head of PMS/Weath: Mr. Saurabhendu Bhushan (Saurabh 8 ‘Name Qualification Bret Experience '* Work experience of over 20 Swurabbendu MBA years inthe banking. and Bhushan (Saurabh nancial services space ‘hushan) (© Worked with Banks such as Deutsche Bank RG and sarcays Bank ie ‘= Handled Family office at ‘arware Polyester Lid 43, Top 10,roup companies /frms of the Portfolio Manager onturnover basis* “Zeroaha Broking Limited 4958.08 2 NiSquare ways 3 amath Associates FETE} oa) 25058 5 ‘eroaha Technologies Prva Limited aa “True Beacon, The Marq, Flor No 19, Vital Maya Read, Bergaur, Karnataka, rd ‘8000 ww ruebeacon com | nfogttveboacon com | +91 86438-03202T 4s 52 53 sa rue Beacon ie “Zerodha Commosites Private Limited 289 F ‘stn Global Ventures Pot td 168 = ‘Rainmater Capital Private Limited ass 8 ‘erodha Secritos Private Limited 2075 10. Vanlavino Cafe? a8 “The above st fs based on the turnover of the group compantesirm of True Beacon Investment Advisor LP as pe the outed accounts for fianca yeor ended 31/03/2022. Detail of services being offered by the Portfolio Manager ‘The Portoio Manager offers portfollo management serves under discretionary, non Aiscretionary and advisory categories. Direct onboarding of cients by Portolio Managers 45. Glens shall have the option tobe on-boarded directly to aval the services ofthe Portoio Manager, without intermediation of persons engaged in distribution 452. tthe time of onboarding of Cents no upront fees sal be charged by the Portfolio ‘Manager ether director indirectly. The fes ad expenses charged by the Portfolio ‘Manager salle specie under the Cent Agreement PENALTIES, PENDING LITIGATION OR PROCEEDINGS, FINDINGS OF INSPECTION OR INVESTIGATIONS FOR WHICH ACTION MAY HAVE BEEN TAKEN OR INITIATED BY ANY [REGULATORY AUTHORITY. {All cares of penalties imposed by EB! or the dection issued by SEB! under the Securities ‘and Exchange Board of india Act, 1982, rules or eguatons made thereunder - NIL. ‘The nature ofthe penaty/direction - Net applicable Penalties imposed for any economic offence and/or for vaton of any secures laws ~ NL. Any pending. material Wigationlegal proceedings against the portato. manager/key personnel with separate ciclosure regatdirg pending criminl cases, if any ~ NI “True Beacon, The Marque, rd Foor, No 19, Via Mala Road, Bengaluru, Karnataka, In "360001 ‘wa truebeadon com | foguebeacon com | +91 26:699.03202True Beacon 55 Any deficiency inthe systems and operations ofthe Portfolio Manager observed by SEB! or any regulatory agency ~ NL 5:6 Any enquiry/adjudiation proceedings ntted by SEB! agaist the Portoio Manager oF ts ‘rectors, Principal Ofceror employee or any person directly or indirectly connected with the Porto Manager o its directors, Principal Offier or employee, under the Securities a xchange Board finda Act, 1982 or rules and regulations made thereunder ~ 5.61 For Portfolio Manager, is dectors, Principal Offiersor employees: NL 5.62 For any person directly oF indiecty connected witr the Portfoko Manager oF is rectors, Principal Officer or employee: NI 6. SERVICES OFFERED 61 True Beacon LP offers Discretionary Portfolo Management Services, Non-Discrtionary Portfolio Management Services and Advisory Services, 6.1.1 Discratonary Portfolio Management Services Under these services, the choice as wll asthe timings ofthe nvestmentdecsons rest solely vith the Portfolio Manager and the Portfolio Manager can eercice any degree of dcreton In theinvestments or management of Portfolio ofthe Client in accordance with the Portfolio Management Services Agreement ("PMS Agreement). Under Osscretimary Portfolio "Management Services, the Portfolio Manager may iwest Cents’ Funds i sted sects, Secures which ae traded on a recognited stock exchange, meney market instruments Lieluing but not mites to, commercial paper, trade bil treasury bills, certificate of deposit and usance bil) units of mutual funds and ater securities as specified by SEI from time to time, onbehalfof Cents, naccordancewitha pplable lows ‘The Securities invested /dsinvested by the Portola Manager for Clients may eiffer from cent to clent. Separate cent-wise account sal be maintsned bythe Portfolo Manager ‘with scheduled commercial bank. The Portfolio Marager’s decision (taken in good faith) guarantee that the Portfolio [Manager wil be able to find a purchaser for such secures or benchmark the pice for purchase for such securities (as there won't bea market forthe same). Cred ick Debt securities ae subject tothe isk of the issuers inability to meet the principal and Interest payments on the oblgations and may alo be subject othe price volatility due to such actors as interest sensi, maret perception or the creditworthiness ofthe ssuer and general market risk Interest Rate Risk Tis risks associated with movements in interest cates, which depends on various factors such as government borrowing, inflation, economic performance ee. The ‘value of investments wil apprecite/depreciate if tre interest ates fale, Feed Income investments are subject to the rik of interest rate fluctuations, which may accordingly increase or decrease the rate of return thereon. Force Majeure Rik In certain cases, the value of securities may be impacted by externa factors such 35| {ets of State eminent domain acts of God, or soveren actlon acts of nature, act of ‘war epidemic, pandemic disturbance which meyaffect the iguidtyof secures, ‘value of underhing ase, copia isk ‘The Chet stands the risk of total loss of valve ofan asset which forms pat ofthe Portfoo oF ns recovery only through an expensive eal process due to factors which by wy of ilutrationinlade detour non-peeformance ofa thie party, company's refuel to rite a Security de t egal stay o otherwise, disputes raised by thd pares. Derivative Risks ‘The Gervatves wil ental @ counterparty risk to te extent of amount that can ‘become due from the party. The ost of hedge can be higher than adverse Impact of ‘market movements, An exposure to derivatives in exes of hedging requiem can “ve Beacon, The Marqus, 3rd Foor, No 19, Vital MalyaRosd, Bengaluru, Kematak, nda "560001 ww ttebeacon com | nflo@rueteacon com | 191 96-636-02202True Beacon 7210 naan 722 7243 7214 lead to losses, An exposure to derivatives can ako It the profits from a genuine investment tansaction. ffclency of a derwathes market depends on the evelopment of quid and filet market for undering securities and als onthe ‘stable and aceptabie benchmarks Reinvestment Rsk ‘This isk rises from the uncertainty nthe ate at which ash lows from aninvestment| may be reinvested. This is because the bond wil ay coupons, which will have to be feinvested. The rate at which the coupons wil be reinvested wil depend upon prevailing market rates a the tne the coupons ae received. Mutual Fund Rik “This isk arises rom investing in nits of mutual funds Rik actrsinherent to equities land debt Secures ae aso applcable to investments in mutual fund unis. In !adion, events ike change In fund manager ofthe see takeover and mergers of ‘mutual funds, foreclosure of schemes or plans, change in government pois coukd afect performance ofthe investment in mutual fund sats Market isk Market values, liqutity and risk: return profile of Investments investment characterises) in equties ae likely to fuctute deyening on performance ofthe Industry, national and international economies, reglations and changes therein domestically and Intemational, evens that are of sigfcant impact such as war, terrorism, sanctions and trade embargoes, natural calamities, ats of God, epidemic, pandemic etc. Market values, iquidlty and yields of fixed and variable income Instruments are lel to fuctvate depending onthe prevaing interest rates inthe ‘market, liquidity preferences, impact cost changes, ratings ofthe isuer or the Instruments, competing instrument, et Stock Specie Risk Performance ofthe isuer companies will have sigifi:ant influence on market prices of ts securities. This wil further depend on, in addon to exteral factors its own ability to perform, management, changes therein, frauds by and onthe management fete. These ae known as intemal sks ‘Transaction and Settlement Risk ‘The Portois faces adalional risks such as timing iss, short delivery or delayed delivery fom markets, reduced baud, ee Portolo Manager Competency Rsk ‘The Portfolio faces risks based on management ard operational efficincis and controls ofthe Portfolio Manager Le, the rk s based on abity of the Portoio “Troe Beacon, The Marqus, 3rd Foor, No, 19, Vita Mala Road, Eengaluu, Karnataka, Inia 36000" wn ttusbeacon com | hfo@truabeacon com | +01 26-630.09202True Beacon 7236 nar 7238 7aa9 "Manager in identifying opportunities or miuding trends and ate investments and/ or earl Iquidations, ether at os ora reduced pros, misudging opportunities completely. Aled Service Provider Risk The Portfolio facesrsks de to othe service providersthat the Porto Manager may ‘engage to render the services suchas banking, brckng, clearing and settlement, custodian serves, courier serves, auditing services ete Portfolio lied Operations Risk ‘The Client also faces risks from usage of technology for recording transactions and accounts, communication of information ta and fro. data computing and storage, leakages of data / information rom various points including atthe Portfolio Manager’ operations ete egulatory Risk ‘Changes made bythe governmentin any ofthe poy parameters, incledingin respect oftanation, et, that affect working of companies hve postive / negative impact on| ‘market oices of those stocks an to that extent, inthe value ofthe Portfolio. Such ‘anges may also appy to the manner in which Portfolio is being operated are on tarability of profits made on dvestmen, tax teatmert for dvidends, et ‘The tox aspetsof anivestmentin shares and securtesia nda are complicated and teach investor shoud have them reviewed by profesional advisors falar with such Investor’ personal ay sitation and with the tax laws and regulators applicable to the investor. The tax consequences for any investment wil depend on circumstances specicto each investor and the ational peculiantes associated with respect othe investments. Further, theresa ik thatthe income taxauthorities may rechoractrze the income/retuns provided to you, which may lead higher incidence of rect nd indirect tax. In certain reumstances where the securles purchased bythe Cllent™may derive their value from income generated from the underyng asset, the income tox authorities may have claims pending the underlying asset, which may impact your Income/tetuns from such asset. ‘vacancy Risk Incertain circumstances, the Securities purchasedby te lent may derive thelr vale {rom income generated from the underying asset. In sch cases, the vale ad return ‘on the securities may be impacted incase the underyng asset isnot able to generate income, which may be due to varous factors. Further, the Pertfolio Manager may ‘offer investment. opportniis to other clients, which may compete with the investment made by you “True Beacon, The Marquis, id Flor, No 19, Vitel Malye Road, Seagal, Karnataka, nda 8000" ww ruebeacon com | nlo@krvebeacon com | +81 $6830-03202True Beacon 7.2.20 Tile Risk ‘Asa Portfolio Manager, we may appoint advisors and service providers to undertake ‘ue digence of underiying ase, however, here sen inherent sk associated with any due diligence exercises asi relies on the venor to provide all information, accurately and ratty. 7.2.21. itgation Rsk “Te value and marketability ofthe Secures or the underying asset may be impacted de to commencement of tigation in elation to the Cen, the issuer of Security or the undedying asset through which the Secures dere their vale. 72.22 Key Person isk Key persons ofthe Portfolio Manager may be involv in various capaci (such as directors or shareholders) with the sur of Secutlespurchased te Client and there ‘may be a potential non-algnment or confict of interest in suh cases. Some ofthe {uanstctons between the Portfolio Manager and the iver of Secures purchased by the Client wil be treated a ested party transactions. Al tansactions of purchase and sale of secures by portfolo manager and its employees who are diectiy inuntedin investment operations shale dscosed ound having confit of intrest with the transactions in any ofthe Cents Portfolio. Futhe, a disclosure of confit intrest elated to services offered by group companies of the Portoio Manager, Hany, shall aso be made 8. CUENT REPRESENTATION 841 Details of llent account activated 1. Detals ofthe clients managed by True Beacon LLP is menttaned below: Associates /| NA NA NA group companies (last3 years) ‘thers (art 3 7 73s ‘Ni Dzeretionaey years) Total 7 1035 ‘i Discretionary Complete ascosure in respect of wansactons with related partes a per the standards specified by the Institute of Chartered Accountants of nda “True Beacon, The Maraus, id Floor, No 19, Vital Mala Road, Bengalis, Karnataka 50000 ww rusbeacon com | info@trvabeacon com | +81 9-638-03202True Beacon 10. un 2 Pease refer to Annexure 1 of this Disclosure Document forth disclosure in ths egard DETAILS OF CONFLICT OF INTEREST RELATED TO SERVICES OFFERED BY RELATED PARTIES OR ‘GROUP COMPANIES OR ASSOCIATES ‘The Portfolio Manager and Its Related Partis/ group compariesassocites are engaged ina broad spectrum of atts in the financial series Sector. The Portfolio Manager may utize Such services of is Related Parties or group companies 0° associates for managing the Portfolios of the lens. These include avaing trang. broking and dstrbution services provided by Zerodha Broking Limited etc. Zerodha Broking Limited hols a eence withthe ‘Associaton of Mutual Funds iningla AMET’ bearing registrazion ne. ARN-163325, valid uni May 2022, and fs therefore eligible to act asa distribution forthe Portfolio Manager. The Portfolio anager may aval the service ofother Related Pais or group companies as may be deemed necessary, rom time to time Insuch scenarios, te Portfolio Manager shall actin 4 fiduciary capacity in relation to the Cllent’s Funds and stall endeavour to mitigate any Potential confict’of interest. that could arse while dealing with such group ‘ompanies/asscates, na manner which snot detrimental the Cent. ine wth the SEB ccular dated 13 February 2020, charges for al the transactions in the financial year (brokerage, demat, custody charges et.) through salforassoxites shal be capped at 20% by ‘value per associate including sel) per service. The Portfolio Manager shal ensue that any charges to sel/assoiate shall not be at rates more thn that ald to the non assocates enti andthe fund and the athe entities with which they are associated maybe entering Into secures market transactions and such transactions wil be based on adequate Chinese walls and the transactions ofthe fund and the transactions of such entities maybe contrary to each other. Pease refer to Annexure 2 ofthis Diclosure Document fr deals ofthe associate / group ‘companies of the Porto Manager. THE FINANGAL PERFORMANCE OF THE PORTFOLIO MANAGER BASED ON AUDITED FINANCIAL STATEMENTS AND IN TERMS OF PROCEDURE SPELIFIED BY SEBI FOR ASSESSING THE PERFORMANCE Pease refer to Annexure ofthis Dicosure Document for thedscosureinthisregard Please ‘note that the financll performance ofthe Prtoio Manager, a declosed under Annexare 3, ‘aces the newly setup portfolio management business fom its ambi. PORTFOUO MANAGEMENT PERFORMANCE OF THE PORTFOLIO MANAGER FOR THE LAST ‘THREE YEARS AND IN CASE OF DISCRETIONARY PORTFOUNO MANAGER, DISCLOSURE OF PERFORMANCE INDICATORS CALCULATED USING “TIME WEIGHTED RATE OF RETURN” [METHOD IN TERMS OF REGULATION 22 OF THE PMS REGULATIONS "Not applicable. Portoio Manager operations has begun inthe year 2022. [AUDIT OBSERVATIONS OF THE PRECEDING THREE YEARS NI. “rue Beacon, The Maraus, 2rd Foor, No 19, Vital Malya Ras, Bengali, Karnak, nd ‘350001 ‘www trboacon com | info@truebeacon com | +91 9-638-03202True Beacon 13, NATURE OF EXPENSES ‘he following are indicative types of costs and expenses fer Clots avaling the Portfolio [Managemen Services. The exact basis charge eating to e32hof the following services shal be annexed tothe Portolo Management Agreement and/ar the agreements in respect of teach ofthe service avaled by the Client atthe time of execution of uch agreements, oy o Investment management and advisory fees 1. The Portfolio Manager’ standard annual fee forthe Discretionary Senvces, Now Discretionary Services and Révsory Services shall ange between 0.25% to 2% pa. of the total asats under management of the Clent on a quarterly basis. The "Standard annval fee shal be agreed upon between the Portfolio Manager and the Cent while executing the PMS Agreement and acded asa schedule to the PMS [ereement. The Portoio Manager shall at all tines comply with SEB) Circular IMD/DF/13/2010 dated October 2010 and StBY/HO/IMD/OFY/CIR/P/2020/26 ated 13 February 2020In respectof the mates deat with by the sald ccuars wth respect to fees ad charges. 2. erfarman/ profit sharing fe of the Porto Manager challbe computed an the basis of ghwater mark principle over the Be ofthe investment, as prescribed by the aforesaid rule The performance / profi shang fe shall be agreed between the Portfolio Manager and the Client whe executing the PMS Agreement. 2. High Water Mark shal be the highest value that the portfoiofaccount has reached, Value of the porto for computation of high watermark shall be taken to be the ‘value onthe date when performance fees ae chard. Fr the purpose of charging Peformance fee, the frequency shall ot be less than quarter. The Portfolio "Manager sal charge pertrmance-based fee only on increase in portfolio vale in excess ofthe previously achieved high watermark 4. High Water Mark shall be applicable for discretionary and. Now-Discretionary Services and not for Advisory Series. Incase of interim contributions withdrawals by Clients, performance fees may be charge afte appropriately adjusting the high water metkon proportionate basis Ccustosin, Reistrar and transfer agent, and brokeragefees: ‘over and above the performance fee and the transacions cst as mentioned above, the Portfolio Monager would recover charges levied bythe custadian for acquiring, holding sale & transfer of investments in de-materiased form (ike custody charges, transaction charges, depostory charges, out of pocketexpenses, et, at actual, aut {ees for auditing and reporting of vidual Client's account and any ther chagesthat the Pertflio Manager may have to incur while runing the porfoio management “True Bescon, The Maras, 3d Flor, No 19, Vital Mala Road, Bengaluru, Karnataka, nda 38000" ‘wane truebeacon com | nfo@truebeacon com |+9196-639-03202True Beacon us. ‘services The above fees, transaction cost and other cherges shallbe directly debited to {the Glens account as ad when the same becomes due for payment. These inhade: 1 custodian/Depostory fees: The charges relating to opening and operation of ‘eraterialied accounts, custody and transfer charges fr shares, bonds and units, dematerilization and ather charges in connection with the operation and management ofthe depository accounts | Registrar and transfer ageat fe: Charges payable to relsvars and transfer agents in connection with effecting transfer of secures and bonds including Stamp charges; cost ofaffdaits, notary chares, postage stamp and courer charges. 1k. Brokerage costs: The brokerage charges woul be payable at actuals. Iu, Other transaction costs: Other charges tke service charge, stamp duty, transaction cots, tumover tax, ex and entry leads onthe purchase and sale of shares, stocks, bonds, debt deposits, units and other ancialinstruments (6) Transaction casts ‘Transactions Cost Brokerage and Jor Transaction cst on transactions woul be levied atte prevailing rates charged by the brokers and for any such other tatermediary (+) applicable goods and serves tax (+) stamp duty (¥ securities transaction tax (+) turnover to (+) any other levies thereon, as may be applicable from time to time (6) Distribution Fees: Fees sal be pad to distributors only from the fees recrved by Portfolio Manager. The Portfolo manager shal ensure that its distributors abide by the code of conduct prescribed by SEB Circulr SE81/HO/IMO/OFA/CIR/P/2020/26 dated 13 February 2020 $n furnish anna alterations of sch compliance within 15 das trom the end of the nancial year "Note ~ Al operating expenses excluding brokerage, over and above the Fes charged for portfoso management sevice, shall not exceed 0.5% per anna ofthe len’ average dally ‘assets under management. ‘so please note thatthe fees charged by tha Portfolio Manager from the client for rendering pontoio management services Is without guaranteeing er assuring, either directly of Indie, any eturn. The Portfolio Manager shall charg no unrontfe,arecty or indirectly, torte cents TAXATION “Tye Beacon, The Marque, 3 Flor, No 19, Vital Maya Read, Bengaluru, Kamataka, na "50000". ww ruebeacon com |info@ttvebeacon com | +01 9639-02202True Beacon 14.1 The information furnished below outnes biey the tax reputions which may be relevant to ‘the investors ad is based on relevant provisions of the Income-tox Act, 1961 ("TT Act”) a5 proposed 1 be amended bythe Finance Bil 2022 “The summary below provides general information on Indian income-tax implications but i ‘nether intended tobe a complete discussion of al tax implications, nor does it purport to be 4 complete desrition of al potenti tax costs, tx incidence and risks inherent on the Acquistion, ownership and sale of indian secures 143 In addition, the comments herein are not binding onthe Indun ax authors and there can ‘bene assurance that the authors wil ot take a position conver to any ofthe comments herein. tis emphasized that neither the Portflio Manager rr any other person involved in the preparation of this document accepts responsbity fr any tax effects or Fables resulting from the purchase, ownership or disposition of ths Indian securities. Prospective Investors should consul ther own tax advisors concerning ter individuol tax consequences oftheleparticuar statins 1144 We donot make any representation regarding any lgainterpretation, Since the information below sasedon celevant provisions as of February 2022, an subsequent changes inthe sid provisions could affect the tax benefit 145 General Taxation: The basis of charee of indian income-tax depends upon the residential "tatur ofthe taxpayer during atx ear, 2 welas the nature the come earned. The Indian {ax yer runs fram Apri until March 31. person who ia indian tax resident sable to taxation in ila on his wordwide income, subject to cerain tax exemption, which are afforded under the provisions ofthe Act. person who seated as non-resident for Inion| Fncome-tax purgoses is generally subject to tax in India onlyon such persons Inia sourced 146 Section $0(2) ofthe Act provides tht where the Government of india has entered into an agreement with the Goverment of any country outside nda or specified territory outside Incia (where the taxpayer isa resent) for granting rele of tax or avoidance of double taxation, the taxpayer may opt to be taxed as per provons of the IT ACC oF the tax lweatyfOTAA, whichever s more beneficial 14.7 This chapter doesnot discuss the tox implications applicable tothe non-esdent Investors Under a beneficial OTAA [Section 912) of the IT Ac], which would need to be analysed separately based onthe spect fat, The Indian Government has deposited the ratified Multlateral instrument ("MU") 10 Implement tax reaty related measures to prevent Base Erosion and Prof Shifting ("REPS") ‘0m 25 lune 2019 with Organisation for Economic Co-operation and Development ("OECD") Inca has notified 93 tax treaties i its ratification and acconingly, india’ tax trates with ‘such countries wlinclude MUI provisions wth effect from 1 Api 2020, ‘This chapter does nat cuss the impactof Mon the lim of beneficial tax reatment under DDTAA bya non-resident ivestor. The same would ned tobe analysed separately based on “rue Beacon, The Marqu, dr Foor, No 19, Vital Mala Road, Eengalu,Kamatata India = ‘360001 ‘won rvebeacon com | nfo@ituebeacon com | +81 36439-03202True Beacon ‘the specifi facts, where applicable. Further, the ax rates mentioned herein are exclusive of applicable surcharge and ess, unless specie otherwise 14.10 Taxation of individual income component: Tax impiations othe following income received by certain categories of cents from investments in sacuritls 3s per IT AC are discussed as follows {W)Dividend Income: With effect from 1 April 2020, dddend distributed by portfolio companies shall be subject to tax inthe hands ofthe shareholders. Sima, avidend dstabuted by Mutual Funds (MFs) covered under Section 1{23D] ofthe Act Is taable in the hands ofthe nitholdrs at applicable rates and oxempt in the hands of Mutual Fund, Further, dividend stbuting company / Mutuel Fund i required to withhold tax {rom dhidend income asunder |. For Resident shareholder: 10% (no surcharge and ess applicable (TDS withholding Under section 198 194K) |For Non-resident shareholer: 20% (plus surcharge and cess) under section 1258 subject to any benefia rate avaiable under the apaicable tx treaty ‘The new regime aso proposes to levy TDS atthe rate of 10% onthe income pad by 2 specie company! MFSt Is resident shareholders resident unitholdersifthe amount ‘of such income exceeds fie thousand rupees ia fnancal year However, no taxshall be equized tobe deducted by the Mutual Fund on income which sin the nature of capital sans Deduction under section $7: The FA2020 alowed deduction of interest expense incurted while earing the dvend income. The expense allowance i restricted to 20% of the ‘ividend income without deduction under section 57. The expense allowance Is not 2 Standard deduction per se ad the shareholder /uitholder would need o establish and demonstrate that interest expense wos actual incurted forthe purpose of earing the ‘dividend income. Further, it may be noted that interest expendture snot likely to be Allowable in the year when no dividend income i receWed by the shareholder / Uunitholer. Hence incase of NI dividend income, the exenditare may not be allowable Roll over benef: Section 80M ofthe IT Act provides for benefit of olover of deduction for the dividend received by a domestic company from another domestic / overseas company ora busines trust (Real Estate Investment Tis / restructure investment Trust). Accordingly, where 2 corporate domestic investors recelvng dividend from 3 domestic overseas company oF 2 business trust, sucr investor shal be eligible for ‘deduction oftaxpaidon dividend income rece {rll aver benefit under Section 0) ‘on further dividend dstuted by them to ther shareholders. Ths Is done 10 avoid ‘azcadng effect of tration on the same dvdend income (WGalns fom sale of secures ~ Characterization of income: Gains arising fom the sleof ‘secures inna (shares derivatives et) may be taxed es Capital Gans (CG) or Business "peared inlet scion 2a heUntTstet nd Tarte of nderohing an Repeal At, 202 “rue Beacon, The Maraue, rd Foor, No 19, Vital Malya Road, Bengali, Karnataka, India| 36000" wun rubeacon com info@truebeacon com | +91 96638-03202True Tre 8 Beacon Income (a under the provisions ofthe Ac, depending on thefts and cumstances ofthe case, “Characterization of income arising frm the sale of Idan secures has been the subject, oflgal debate, The CADT sed Cculae No 42007 dated 15 une 2007 outlining certain Juda principles pronounced by various cours an the determination of whether shares ae held as stockin-trade or held as investments. The Greular stats that ro single Principles determinative and thatthe specifi facts and cicumstances ofeach ase are require to be considered inorder 1 make a determination of whether the shares held ‘would be regarded as stock in-trade or investment. The nature of income from the disposal of secures will be dassified 25 66 or BI depending on whether the investments ae held as asst, investments with the object of eapital appreciation or tock in trade forthe purpose cf rade / adventure, ‘The folowing conditions are tobe generalyconsidere for determining the nature of such income! |. The motive of the enty Isto earn profs through dividends, or fom capital appreciations ‘the magnitude of purchases and sales andthe ratio etween purchases and sles ii, Intent ofthe assessee ass evidenced by the documents records Ie. Whether the charter documents author any suchactvty ‘Volume, frequency, continuity and regularity of transactions of purchase and sale White the above discussion f preminanty inthe context of transactions related to shares, on pines it could equally apply even to dervatves. Therefore, nthe context of derivative transactions, given the short duration ané nature ofthe transactions ii Tikey that te transaction would be considered as giving rise to BI rather than income from 6. Furthermore, the CBDT has provided futher guidance on the mater vide crular No.6/2016 dated 29 February 201628 follows: |. Where the taxpayer opts to treat listed shares an securities as stock in trade the Income aring from transfer of such shares / secures would be treated a its B tthe txpayer desist reat income ariig from-he transfer of sted shares and secures held for more than 12 months 35 CG, the same shal not be disputed by thetaxatfeer. However, sucha stand adopted by the assess wilemain applicable In subsequent asessmentyeasalso and cant be tered. con, The Marque, rd Floor, No 19, Vital Maly Road, Bengaluru, Karnataka, nia 6000" ‘wanervebeacon com | nfo@itvebescon com | +01 96639-03202True Beacon 1a. Inallother cases the nature ofthe transaction shall continue tobe decided basis the facts ofeach particular case ‘Te above referred ciculeappied to lsted shares and secures. Therefore inorder to bring partyin taxabilty of income/loss arising from transfer of usted shares the CBDT issued ereular No 225/12/2016 dated 2 May 2016 determining the tactreatment of income arising from transfer of usted shares for whch no formal market exist for wading, {C8DT vide this cca lars that income arising from ransfr of unsted shares woul be considered under the nead CG, respective of period holding with view to avoid dsputes/tgation and to maintain a uniform approach, However, CRDT carves out thee exceptions wherein namely fs caifcatin shall not apply, |. geowineness of transactions in unlisted shares ites questionable i transfer of unisted shares related oan sue pertaining to iting of corporate vel and 1. transter of unsted shares ls made along withthe control and management of underting business ‘Thus itis important to clearly understand the intent fie ofthe aforesaid elas by (CDT from time-to-time and ta interpret ina atonal marner where gin arising fom the sale of securities should be clasfied under the head CG or B (Ga) Capital Gains: A pr Section 45 ofthe It Ac, any profits cr ean arising rom the transfer of capital assets are chargeable ta income-tax under the head ‘captl gine’, Section 4B ofthe IT Act provides that income chorgeable a5 CG she diference between the full ‘value of the consideration ceived or acerued onthe transfer and the cos of acquisition ‘of such aset pus expenditure in relation to such tranler (indexed incase the shares, being listed shares are held fr more than 12 months and purchased in INR. United shares i not held for more than 24 months wil be + short-term capital aset and therefore not eligible for indexation ‘The sale of secures woud be taxed as unde in the case of eden investors Type [Period of | Taxrate [fain | Hoang | Short: [12 months or | 15% in case of equity shares or units of an equity-oriented term | es” for ted | und sted on any econnid sok exchange in ini and shares and. 24 | theses hago ST months or les 2 prod ing of 2 non onadreone case of sae or sce of ainen compar tens eoened Sock exthangs ir Unto UT Unt ef an ty Ort Mua Fun a ro Coupan Bonde Inmet ‘hie shares, gored consdrede Mente sa canned Somat ster seies “True Beacon, The Marq, 2d Floor, No. 1, Vital Mays Rood, Eengalrs, Kamat, India "560001 wu ttubeacon com | info@trueteacon com | +91 96639-03202True Beacon for unlisted | Ordinary rate of tax applicable to the respective investors Sues le: atthe rate up to 20% er crporate nestor, 0% or partnership and lint tty partnerships and atthe ‘pple sla rates for ddl investor Incase of Stare that are not sted on any recognised stock ‘xchange in nda and ince fed shares being sl/ eanstered ina transaction not chargeable 0 STT ‘org: More than 12 | 10% in ease equity shares are Tated on any recognised term | months for | stock exchange in india and the purchase and sale listed shares | transaction of such equity shares is chargeable to ST? ‘and more than | Further, LTCG shall be chageabe oly in ease where the 24 months for | capital gain exceeds INR 10,000 (Indian Rupees One listed shares | Lakhs ony Lower of 10% (without cst indexation) and 20% (with ost indexation) in case equity shares are Usted on any recognised stock exchange but transaction of sale/ ‘wansfr not chargeable to ST. 20% (ater considering, indexation) for equity shares Ind, “Gung on sole of securities would be taxed asunder inthe case of aon vesdent investors Type | Period of | Tact | ofan Shor] 12 months or | 15xn ase of equ sharesor unis fan equlyorented term | ess for fisted | fund sted on any recognized stock exchange in nia and shares and 2 | the sale chargeable to STF. ‘months or less for unlisted | Ordinary rat of tax applet the respective Investors shares ie at the rate of 40% for carprate investor, 30% for parnerships and at the sopable sab rates for other oncorporate investors tease of shares that are not sted on any recognizes sock exchange In india and in case of listed shores being sold! transfered in a tWansaeton not chargeableto ST [Tone | More than” 2 | 08 in case equity shares are Usted on any recognized term | months for| stock exchange in India and the purchase and sale "sted shares | transaction of such equity shares i chargeable to STT. and more than | Further, LTCG shallbechageabe only in case where the “rue Beacon, The Margus, dr Foor, No 19, Vital Mala Road, Eengalun, Kamatata, Ina = ‘360004 ‘wane rvebeacon com | nfo@ituebeacon com | +81 96499-03202True ) wy “Tue Bescon, The Marque, 2d Flor No 9, Vital Malye Road, Gangslur, Kamataka, nd Beacon Type | Period of | Taxvate of in | Holging 724 months for | capital gain exceeds NR 10,000 (Indian Rupees One untsted shares | Lath only) 10% in case equity shares sted on any racogised stock exchange bur transaction f sale/ transfer not chargeable {oSTT (without ving effect to fst and second proviso to Section 48) | Gains on the sale of shares of unlisted companies are subject to tax 10% (without ghing effect to fist and second proviso to Seton 8) Business Income: As siscussed above, the gins on sale of derivative contracts inthe ‘utures Segment should generally be characterized as Bland the same would be taxable atthe ate upto 30% or ether ordinary applicable rate However, where the derivative contracts are entered into by 2 person, are settled ‘otherwise than by delivery of transfer of the shares, ima be lassiied a speculative Income, whiens special ass of (ths cass of 81 cnt st oft losses fom non speculative income steams and loss can be carted forward only forfour years) However, where the derhatie contacts are enteredintaelectronzally through a broker sub broker on a Stock Exchange, where the broker prvides atime Stamped contract ‘ote, withthe PAN of the cent thereon then the income will not be considered as speculative income ‘Where the Portfolio Manager adopts certain strateges (ay ‘Long Shor’ which invotves ‘Smultaneous purchase/sale of secures and dervative products, it might be possible that the tax authorities could construe the same as trading Income” and tx i as Businessincome ie, at higher tax ates) Interest income: assfiction fintrestincome isa matlerof iputewith contradicting Juhl precedents Whether interest income would be asessale 25 busines income or Income from other sources would depend upon the nexus thas with the azessee’s business, Interest incomes taxable atthe ordinary rate tax applicable tothe respective Investors L., upto the rate of 30% fr Indian resident corporate investors, 30% for Partnerships and atthe applicable slab ates fr indi investos In case where the sted debt secures (Including 2er0 coupon bonds) are transfered, any gain derived from such vansfer shall be taxed upto the rte of 30% as short-term capital gains where the peri of holding is 12 months oles] and atthe rat of 10% as long-term capital gains [ere the peried of holding is more than 12 months "50000", ww rusbeacon com |nfo@trvabeacon com | +01 $6-839-03202True Beacon Income tax provisions applicable to Non-residents in respect of receipt of income from ‘ied income products are summarized below (2) lo terms of Section 315A of the IT Act Interest cm monies borrowed in foreign ‘utreny (other than interest referedto in subsequent paragraphs) istaxable at 20% (subject to any tax treaty (b) In terms of Section 11588 of the IT Ae, income ofan asesse, being an overseas financial organization Offshore Fund) by way of income received in respect of units purchasedin foreign currency or Income by way flan term apt gains arsing on transfer ofits purchase in foreign curcency, t's charged @ 10% subject tax treaty benefit i any. The payor i required to witold the applicable taxes. No ‘eduction shall be alowed against this income w 5280s 44C ors. §7() or 57 or ‘Chapter VFA. No indexation shal be allowed on TCS arising on transfer of uns {©} Interms of Section 115AC ofthe IT At, income of on-esident by way of intrest ‘on bord of an indian Company issued in accordance with the notified Scheme Le, "issue of Foreign Currency Exchangeable Bonds Scheme, 2008'/'ssue of Foreign Ccurency Convetbie Bonds and Ordinary shares (Through Depository Receipt Mechanis)Seheme, 1995/ Depository Receipts Scheme 2014’ oron bondsof public sector company #0 by the government and purcrased by the investor in orign Cirreney or income by way of dividends on GDM er income by way of long term aptal gains asing on vansfer of abave bordsor GW, willbe taxed at the rate of 10% (plus appiable surcharge Health and Education cess) subject to tx treaty ‘benefit if any The payor isrequred to withhold the applicable taxes. (0) tn terms of section 11580 ofthe I Act, Income ofa Foreign Institutional investor received in eespect of securities other than units referred in Section 115AB) 25 ‘efined under the Securities Contracts (Regulations Act, 1956 staxed @ 20% (pls applicable surcharge and Heath and Education cess subject to tax weaty bent, f any. The payors required to withhold the applicable taxes (6) Similar provision ie avaiable fr other than Fi invests who invest in Long-term ‘Bonds of indian company in foreign cutency, wehholdng shall be done under Section 1981C of the IT Act at 5% (plus appicale surcharge and Health ad Eedcation ces) subject to satisfaction of ertain conditions interest to be calculated atthe rate approved by Central Goverament, having regards tothe terms of the bonds and ite repayment), subject to tax testy teneft f any. The payor shall withhold applicable taxes, (6) Anyinterest (other than above) on loan received in na currency is taxable at 40% (subject to tan treaty benef, fan). 14.11 Rate of surcharge ‘The ahove rates of ncometaxin this document shall be inctensed by the following surcharge ‘on income tax and education cess on income tax and suchare “rue Beacon, The Maraus, rd Foor, No 19, Vital Mala Red, Bangali, Karnataka, Ind "360001 ww trubeacon com | flo@iuebeacon com | +91 35-698-03202True Beacon ‘As per the Finance Act, 2021 with | Surcharge on | Education Cats on ‘effect from 1 Api! 2021 Tncome-tax income-tax and surcharge Rate of surcharge on indian companies 7% % with income exceeding INK 10 millon bates than INR 100 milion | Rate of surcharge on Indian companies BK % with income exceeding INR 100 millon Resident companies opting for faration| 10% % under section 1158AA and. section 115808 7 Rate of surcharge on Foreign companies % ae with income exceeding INE 10 millon | Duties than NR 100 ition ate of surcharge on Foregn companies % ae sith income exceeding INR 100 mation Tate of surcharge on Partnership frm 7) 29% ae UP wath income exceeding, INR 10 | milion | indiiduas HUF ROP BOK where the | 10% 75% 72% me total income exceeds INR Millon 10 | /37% Millon / 20 Millon / 50 Mion (Pease refer othe note below) Note: The enhanced rates of surcharge (essential the 25% and 378% rote of surcharge pplicbl for income arecter than INR 20 milion and INR 50 milion respective), shal not ‘onply for dividend income, capt! gon orsing to Fl on trans of any secures and incase ‘ofcaptal gains ering onan on market tronsfer ofthe folowing secures (where applicable szeuiestronsetion tax hasbeen oid) as refered toinsecton 111A ond 1124 ofthe ITA f= Equity shores Unt of an equisyorente fn {© Units ofa Rea stote investment Tus (RET o Ifastature investment Trust (nT) Further, 2s pe the Finance il fortaxon al frm of on term copia gain shall be capped to 15%. Once effective, th hi transactions completed on ot after {Apri 2022, 14.12 TaxCollected at Source With effect from 1 October 2020, whare the Seller of gcods receives any amount 3 consideration forsale of goods ofthe value exceeding INR' milion such Selle isrequired to collet from Buyer a sum equal to 0.1% ofthe sale consideration, exceeding INR 5 milion, ‘This shall ot be appicable case Buyer sabe to deduct axes at source fromthe payments rade tothe Seller and has deducted such amount. “True Beacon, The Marq, 3d Flor, No 19, Vit! Malye Read, Bengaluru, Kamaaka, rd "000" ‘ww ruebeacon com | info@tivebeacon com | +01 96-639-02202True Beacon Seller forthe purpose of TCS provisions unéer section 205C(IH) of the TAhas been defined tomean a person whose tta sales, turnover o gross receiptsexceeds INR 100 milion during the financial year immediately preceding the financial year in which sal of goods scarred “Goods for the purpose of TCS provisions could include shares and secutties. There are curently alternative interpretations ofthe applicability of TCS to transactions in securities including qualifying ertera fora “Selle. “The CROT, vide Circular No, 17 of 2020 (dated 29 September 2020), has caved out certain transactions wherein the provisions of section 206¢(H) of re ITA shall not apply. Ths inter tia incuds transactions in securities and commodities which are traded through various Fecognized stock exchanges or cleared and settled by the recognized clearing corporation, incling. recognized stock exchanges or recognized caring corporation located In International Financial Service Cente. Accordingly, where transactions in securities an commodities are traded through recogized stock echanges, the provisions of ction 206C(2H) shall not apply. 14.13, Tax Deducted at Source (TOS) under section 1840. With effec from 1 uly 202, a buyer while making payment fo resident seller on purchase of {gonds having value exceeding ty lakh rupees ring the Hnaacal years fequredto witha taxat the rate of01% under Section 1940. the FTA ‘Buyer forthe purpose of section 1940s defined 25 a person whose total sles gross recelpts ‘or turnover from the business carried on exceeds INR. 100 milion during immedately preceding final year in which the purchase of goods is cared out ‘Goods forthe purpose of section 1940 could Include stares and securities. There are current alternative interpretations ofthe applablity to trnsictionsin secures incuding ‘qualifying criteria fora "Buyer" ‘CODT has also sve 2 caifieatory cular no. 13 / 2021 dated 30 June 2021 to address ‘various iss in elation tothe applicability of Section 1940. As per the sald cular, no TDS ts 1940 shall apply n aze of transactions in secies and cemmosites whch are traded {through recognized stock exchanges or tleared and vetted by the recognized clearing ‘corporation including recognized stock exchanges or recognised leering corporation located in FSC. This inline withthe CHOTcreulr issued in the context of Section 206C(1H), Accordingly, where transactions insecurities and commodities are traded through recognize Stock exchanges, the provisions of section 1940 shall not apy in the hands of buyer. Further, TOS under Section 1940 shal not be applicable where the buyer I a non-esdent| and the purchase of goods isnot effectively connected tos permanent establishment iningia (itany) “True Beacon, The Marquis, 3rd Foor, No 19, Vita Malye Road, Sengaluru, Kamataka, Ina ‘30001 ‘wanrvebeacon com | nfo@tvebescon com | +91 96839-03202True Beacon Withholding of taxa higher rate [sper Section 206AA of the IT Act, where a recipient of income {whichis subject to ‘withholding tax) does not funsh its Permanent count Number("PAN), then taxis required ‘ohe deducted bythe paye atthe higher ofthe following, I) rates specified in therelevant provisions ofthe Act (i aes in force; ori at 20% (wenty per cent) 38 (five percent In case of withholding of tox under Section 1540 n case of romrresidents not having a PAN, this provision requiring tax deduction at a higher rte shal rot apply they furnish certain preserbed infomation / documents (Including ther tax residency certfeate. Accordingly, incase of recipient who donot have a PAN, tax shall be withheld at a minimum rate of 20% (twenty per cent) / 5% fie percent) for TS under Section 1940, except incase Of non-resident investors who fumishes certain prescribed information /- documents (including thelr tox residency certeat) ar provided by such Investors being nonresidents Separately, under Section 20608 of the Act, where the recifent (other thana non-resident not having permanent establishment in Indi} has not fied its income tax return for two Finacial years preceding the relevant financial year and sich recipient has suffered withholding taxer tax hasbeen collected from sch recpientcfan amount aareestire to INR §h.oMN genre in aach the et hun oan year then osvptinenen of enrtain spied payments tox shall be witeld at higher ofthe follosing rats: + twice the rate provided under the IT Actor + twice the rat ortesin force; or + therateot5%, Further, where the recipient has nether furnished is PAN (wich ental withholding of ax at ‘mini of 20501 5%, athe case maybe, under Section 2058A) nor fled stax etur or {ast wo financial years, taxshall be withheld at higher ofthe rates under both the provisions Under the Finance Bil 2022, i is proposed to amend the grovsions of Section 20648 to provide that higher withnldng tax ate shall apply ony in case of persons other than anon Fesident not having 2 permanent establishment in indi) wo has not fled its income tax return forthe immediately preceding final year for which the time limit under Section 139(1)has expe, and such recipient has sulered witholding tax or tax has been colected from such recipient of an amount aggregating to INR 50,000 ormore inthe relevant preceding ve. Deemed income on investment in shares / secures In terms of Setion 562} of the IT Ac, shares / secures ae received for less than the fairmarkt value ofthe shares / securities (computed as per preserbed rule) the aiference "poesia cas ofr on gr band feet under Seton Af he et “Tue Bescon, The Marq, Jd Flor, No. 19, Vita! Mallya Read, Bengal, Kamat, dia "360001 ‘www uebeacon com | info@etuebeacon com | +91 9639-03202True Beacon between the price paid and fair valve thereof shall be deemed as ordinary income ofthe recipient. Separately, shares other than “quoted shares” are transfer for less than the fir valu of the shares (computed as pr prescribed ules, the aval f such unquoted shares shal be fleemed tobe the sale consideration forthe slr, for compating ts capital gla for inion tax purposes. “Quoted share” i defined a5 “the share quoted on any recognised stock texchange with regularty from time to 8m, where the quotation of such share is based on turenttransacton made inthe ordinary course of business.” Bonus Stringing ‘According to Section 948}, in case of units purchased within 2 period of3 months prior tothe record date (for entitlement of bonus unt) and sold/ransfered/redeemed within 9 months after such date, the loss arsng on transfer of orginal units sal be ignored forthe purpose ‘of computing the income chargeable to ta, The los 0 ignred shal be deemed as cost of cquistion of such bonus uns 14.15 General Ant Ayoidancs Rules (GAAR) ‘he Finance Act, 2012 had introduced General Ant Avoidance Rules (GAAR) into Act, which, sulcequent to the amendments introduced bythe Finance Act, 2015, has come into effect feom Ap 1, 2037 | pr the provisions of IT Act Indlan tax authorities have been granted wide powers to tax “impermisiie avoidance arrangements’ inclading the pover to disregard entities in 2 structure, reallocate income and expenditure between partis to the arrangement ater the tax residence of such entes andthe lgal situs of assets involved, treat debt as equity and vice versa, The GAAR provisions are potentially applicable to any Yansaction or any part thereof “The term “impermissible avolance arrangement has been defined to mean an arrangement ‘where the main purposes to obtain a tax benefit, and it (a) Creates rights, or obligations, which are nat ordinarily created between persons dealing atamslength, (0) Results, cvecty or indirect, inthe misuse, or abuse, ofthe provisions ofthe IT Act {e} Lacks commercl substance ore deemed to lak commercial substance; or {G) Is entered into, or eared out, by means, or in a manner, which are not erdinary employed for bona fide purposes Further an arangement shallbe presumed niessits proves the contrary bythe taxpayer, tohave been entered into, o cated ou, forthe main purpse of obtaining a tax benef, the main purpose of 2 step in, or a pat of, the arangerent isto obtain a tax benef, notwithstanding the fact that the main purpose ofthe wok arrangement isnot to obtain a taxbenett Tre Beacon, The Marquis, Sv Floor, No, 10, Vital Maya Road, Bengatiu, Kemet, Inia ‘58000 ‘wars traebeacon com |nfovebeacon com | +81 96639-08202True Beacon Incase the GAAR is applied to any transaction pertaining to the Fund, could have an adverse impact on the taabity ofthe Fund and/or its investors and rece, impact the returns tothe Investors. Itis provided that GAAR shal not apply intr ai, to arrangements where the agregate tax benefit ina relevant year, toll the parties involved, does notexceed INR 3,0000,00(Inan Rupees Thirty millon), 14.16 Other applicable taxes (a) Wealth taxhas heen abolished by the Finance Act, 215, (&) Securities Transaction Tox ("S17") As sicussed above the concessional ateforshort term capital gains and long term capital gains would be applicable ony if the sale transfer af ‘the equty shares takes place ona recognized stack exchage' India Al transactions entered ‘ona recognised stock exchange i nda willbe subject to ST levied onthe transaction value atthe applicable rates, (o)The rates ofSTT areas follows 1a) [Purenase of an equty share in a company where|0i Purchaser the transaction sentered into in recognized tock lezhange and the contract is settled by actal ‘delivery or transl of such shares | 16) |Purchase ofa unit of aneauity oriented and where| | Purchaser ‘the transaction entered intoin a recognized tock lexchange and the contract is settled by actual | [aetvery or wanstrof such units TL) |Ssle of an equity hare wa company where the|O Seller tronsaction is entered into na recognized stock feachange and the contract is setted by actual Aelvery or transtrof such shares [oy [Sale ofa unit ofan equity oriented fund where the|001 | Seer Iwenstction is entered ino ina recognized stock change and the contract is sated by actal delivery or transfer of such units 13 [Sale ofan equity share loa company/ unit of an|0125 Seller equityoriented fund where the transactions entered into in a recognized stock exchange and “True Beacon, The Marque, ed Floor, No 19, Vital Malye Rosd, Eengalur, Karnataka, nia 30000", ww rubeacon com | nfo@ruebeacon com | +91 96838-03202True Beacon the contact i settled otherwise than by actel Aelvery oF transfer of shaes/ unt. ‘a0 “Sale ofan option insecure (STT willbe payable ‘on the option premium) 005 Selier ‘a0 Sale ofan option insecurities where the option ‘exercised (ST wil be payable on the settlement price) ows Purchaser rae Sale ofa future in sacartes ‘selier 'Ssie of units of an-equry-oriented fund to the Mutual Fund 'seler @ Sse of waisted equty shares by any holder of such shares underan offer forsale tothe public including in an 0 and where such shares are subsequently lend a rrngnived eorkmuchange ster “The amount of TT paid in respect of the taxable sects transactions entered into Inthe course of business during the previous year can be lamed as deduction ithe income _arsng from such taxable secures transactions I included in the income computed under {the head Profits and goin from busines and profession [Section 36(1\0)}- 14.17 Stamp Duty and Transfer Tax {a} The Finance Act, 2019 has amended the above aw to grvide that stamp duty shall be levied uniformly throughout the country a Wansfer of secures in physical as well as demeterlzed fom {) Applicable stamp duty under various scenarios are tabulted below: Debentures ‘0.005% —[isver 2. Transfer of securities “True Beacon, The Marquis, 3 Flor, No 19, Vital Maya Read, Bongsu, Karnataka, nai = 58000" ‘wars rvedeacon com | nfo@trvebeacon com | +91 96699-03202 elseTrue Beacon [Shares ‘On delivery bass ‘ism | Buyer 1 J Onnon-delverybass | 003% | Buyer Tn physical form ‘ISH | Seller Tonsteror Debentures ‘Marketable ‘0.000i% | Buyer Non-marketable D0001% | Seller ansferor (6) stamp duty wit imposed on purchase of mutual unds~eguty and debt funds — from July 1, 2020. Aspe EB 0.05% stamp dty wile levied on purchase of mutual funds, incuding lamp sum, Si, STP, and dividend reinvestment. Ii, however, not applicable on redemption of unt: Meanwhile, stamp duty of 0158 wil ako beimpasedin case of transfer ‘of units between demat accounts, () There con be no quaronte thot the above postion regarding taxation of the Client would necessoriy be accepted by the income-tax autheriies under the IT Act. NO ‘representation i made either by the Portfolio Manager or ny employe, partner or agent of the Portfolio Manager in regard to the acceptoilty or aterwise of the above postion ‘regording taxation ofthe Client by the ncome tax outhores under the IT Ac. Prospective Investors are urged to consult thei own tox adisers inthis regard 435. ACCOUNTING POUCiES 15.1 The following accounting plcy wl be applied forthe investments fens: 152 Books and Records would be separately mlatained inthe nameo the lento account forthe assets and any addons, income, receipts and disbursemens in connection therewith, 35 rovied by the PMS Regulations. Accounting unde the respective Portfolios wil be done in accordance with General Accepted Accounting Principles in Ia 153 ThePortfolo Manager and the cient can adopt any specific norm or methodology for valuation ofiavestmentsor arcountng the same may be mutually agreed between them onacasespecifc bass 154 The Portfolio Manager shall keep and maintain proper bcoks of accounts, record and ‘documents fr each Cent so as to explain transactions foreach Client and to dsclse at any point ofthe Portfolio halaing ofeach lent. 415.5 The following accounting polices wl be applied forthe Portfo investments of Clients (3) Basis of accountng “True Bescon, The Marquis, 2d Floor, No. 19, Vital Mallya Road, Bonga, Kamal, naa ‘360001 ‘wane trvebeacon com | info@ituebeacon com | +81 86:638.03202True Beacon ‘Te financial statements ate prepared on an accrual bass of accounting under the isto cost convention. (0) Use of estimates ‘The preparation of financial statements requires the manegement to make estimates and assumptions that aflect the reported amount of asets and labities as ofthe date ofthe financial statements and reported revenues and expenses forthe yer. though these testimates are based on the management's best knowledge of current events and actions, lucertainy about these assumptions and estimates coud result in outcomes diferent from the estimates. Difference between actual results and estimates are recognised inthe period in which the results are krown or materialise (9 capital {apita represents ntusions (net of withdrawals, if any of Funds/Securtes contributed by ‘the Cent under the PMS Agreement. (2) tvestments ‘counting for investment transactions: Purchase andsaleof investments are recorded on trade date bas, after considering brokerage, any Secutes Transaction Tax eved on purchase/sale of Secures during the financial year i recognized as an expense inthe books of accounts. Investments a= atthe Balance Shest date are relleced at Cost Investments are allocated to the Cent hased om pre-determined enters at weighted average price ofthe days transaction Bonus its and splits are recorded onthe respective ex-ctes notified by the Company. (o) Revenue Recognition (i) Profit or loss on sale of investment is recognised onthe date of transaction and is determined by applying the Fst in Fst out prince |i) Dividend income is accounted fr when unconditional ight to receveis established, (i) Intoreston Fixed Deposits acruedon atime proportionate basis atthe urderying 2 In respect ofalinterest bearing investments, income shallbeacrued ona day- ‘today bass 35 ts earned, Therefore, wien sich investments are purchased, Intecest pad for the period from the las interest de date upto the date of Purchase should not be treated a5 cost of purchase but shall be debited to Interest Receivable Account Simian, interest recelvedat the time ofsal forthe period from the lst interest ve date upto the cate of ale must not be treated {sn adi to sale value but shal be ceditedta Interest Receivable Account. in ease where debt secures have matured and remained overdue, interest is accrued only upto the date of maturity ofthe respective secures or as per {greed terms with the investee companies, Penalintrest, interest forthe period Subsequent to the maturity date ofthe securities and premium on redemption ‘ete af recognised on realization basi. For moratorium period, interest is “Tre Beacon, The Marquis, Sr Foot, No 19, Vita Maya Road, Eengaluru, Kamataka, Inia - 50000" ww uebeacon com | ifo@irusbescon com | +91 96-630-03202True Beacon ‘accrued ont if confirmed by the ivestee companies In case of uncertainty on recovery of overdue interes the same i accruedon receipt bas ». Portfolio Management Fees: Portfolio management fees could incide a fed management fee and a variable performance ‘ee. The amount of fixed and ‘arable fees will be as agreed with the client and defied In the Client ‘agreement. sues related tothe frequency at which fees are charged and how they are calculated wil alo be as defined inthe Client Agreement with each invidval client. The fied management fee will be as agreed inthe Client ‘Agreement terms and conditions an is payable monthly. The performance fees ‘a5 agreed with the clint in the Client Agreement wil be based on returns over & hurdle rate as agreed In the Client Agreemant, with 3 high watermark Performance fees wil be charged on perlomance over the hurdle rate, management fee and any costs of trading. They wil be charged quartery oF annually (0) expenses ‘llexpenss are acerved and acounted on following bass ‘adit Fees ‘Aloeated based on pre determined eter, [Depository charges EAE actals based on actual irwoice received fom Irancactan chargoe the Cattodans [Management Fees 8) Accrued in accordance ‘with the Aareement| Performance based Fees _| entered with the Cent Secures Transaction Tax [At actuals on basis of location of investment (8). Provision fortax "No provision for tak has been made on the income earnec dig the perio since as per the PMS Agreement, ll tx lables are the Cents sole responsibility, Tax deducted at source on interest income i recorded on confirmation obtained from Bank (ua Ai) The Portfolio accounts ofthe Portfolo Manager stall be audited annually by an independent chartered accountant to ensure thit the Portfolio Manager has followed accounting methods and procedures and that the Portfolio Manager has performed his duties In accordance wity the law. A certificate to thi effect if Specified, tobe submited to SEB! within 6 months af close of Portfolio Manager's accounting period. (i) The Portfolio accounts of the Portfolio Manager shall be audited annualy by an Independent chartered accountant and a copy of the certificate issued by the ‘harered accountant sal be gven tothe Cent (i) The client may appoint a chartered accountant to audit the books and accounts of the Portoio Manager relating to his ransactions and the Petfllo Manager shall co-operate with such chartered accountant in course ofthe audit “rue Beacon, The Marque, ed Foor, No 19, Vital Malye Road, Gangs, Karnataka, ni 300001, ww tusbeacon com | info@truebeacon com |+91 96838-03202True Beacon 164 162 ‘The accounting policies and standards as outined above ae subject to changes made from time to time by Portfobo Manager. However, such changes would bes conformity with the PS Regulations Name, address and telephone number af the avestor Relation Officer / Compliance Office ‘who shall attend tthe Investor queries and complaints. Name Ms. Tanwisheth Designation Associate Vice President Lega and Compliance dress ‘he Marque, floor, No. 19, vital Malva Road, ‘Bengaluru, Karnataka $6001 Inia Telephone number +91 9067540000 E-mail address tanviatruebeacon.com Grievance redressal and dlsputesetlement mechanism ‘The objective of revance redvessal system sto ensure thatal dents are treated arly atl times and tht any complaint aed by the cents ate dealt with courtesy ad in time. The Portfolio Manager shall endeavour to addres al complaints regarding series, defcences for causes for erevances, fr whatsoever reason ina easonatle and timely manner To ensue the same, the following system shal be putin pac: (0) Thelen should promptly natty any grievances to the Compliance Officer in wing ving sufclent data to enable the Portfolio Manage to take necessary steps. (©) The Compliance Ofer, on receipt of any suchgrievarces, shal take prompt action to redress the same no later than 1 month from the date of receipt of compliant. The Complance Offcer shal also Inform SEBI about the number, nature ad other particulars ofthe complaints received (0 tthe grievance persists, al aims and disputes arsig out of or in connection with the PMS Agreement ofits performance shal be settled by arbitration by 2 sole arbitrator mutualyaceptabie tothe Parts to sich arbitration. the Paris fll to Beree onthe appointment of a soe arbitrate within 30 days ofthe dispute beg Feferred to arhitration, the sole arbitrator shall be appointed in accordance with the Dbivation & Condation Act, 1996 as amended fram time to time. The arbitration shall be governed by the proviions of the Abiatin & Conllation Act, 1996 a5 ‘amended from time to time and uniess otherwise agreed by the Parties to such rbitation, the arbitration proceedings shallbe held inBengalirv and the proceedings Shall be conducted la English language. Any actin or suit involving. the PMS ‘Agreement with a Cent, oF the performance of the PMS Agreement by ether Paty of ts obigations wil be exclusively in courts locatedat any place In indla subject to the jrsdction clause in the PMS Agreement. A the legal actions and proceedings ae subject othe excuse jurisdiction of court in Bengaluru only and are governed by nian ws. “True Beacon, The Marqus, rd Floor, No, 19, Vital Maya Ros, Bengali, Keratak, In 50000" wu rusbeacon com | info@trvabeacon com | +91 9639-03202True Beacon (4) Aterntivey, with effect from September 2011, SEB has aunched a web based centralized grievance system ealed SCORES ie, SEB Complaints Redresal Sytem, for onine fling. forwarding and tacking of revolution of investor complaints. The Cent may also make use ofthe SCORES fact for any excalations on redressal of thelr grievances. Following Is the link to vist the website and inform their lspute/compaints against the company ‘tps /scores gov. infscores/eomplantRegister htm (4) Inaccordance with the SBI circular SEBY/HO/IMD/IMO$1_OOF7/P/CR/2021/681 dated 10 December 2021, the folowing information shall be available on the website of the Portfolio Manager -hty//truebeacon.com/: (). Theinvestor charter prescribed by SEB: and (i) Monthy data on all complaints ecsived against he Portfolio Manager, including SCORES complaints, by the 7 day of every month 16:3 Ant-Money Laundering Complinc 1 The Government of India has put a policy framework to combat money laundering {trough the Prevention of Money Laundering Ac, 2002. Prevention of Money Laundering ‘Act, 2002 an the rules notified there under eame into elect fom 1 ul 205. Director, AUAN, and Director (Enforcement) have boon confered with enclave and concurrent powers under relevant sections ofthe Prevention of Woney Laundering Act, 2002 to Implement the provisions of the Prevention of Noney Laundering Act, 2002. CConsequenty, S€8i has mandated that all registered intermediaries formulate and Implement 2 compretensive poley amework on antimoney laundering aed adopt "now Your Customer YC" noms 2. Further, E61 vide Creuar No. SEBY/O/MIRSO/00S3/Cit/P/20}8/104 dated 18 October 2019 which supersadesalthe eater ercularssved 3 'Master Circular for Guidelines on ‘Anti-Money Laundering (AMI Standards and Combating the Financing of Terrorism CFT) {Obligations of Secures Market intermediaries under the Prevention of Money {Laundering Act, 2002 and Rules frame thereunder’ consolidating all the ‘equcementsinstructons/obligations of securities market intermediaries 3. Acconingly, the investors should ensure that the amount invested by them i through legitimate sources onl and doesnot invoke an are not designed forthe purpose of ry contravention or evasion of any ac, rules, regulations, rotifcations or directions ofthe Drovions of income Tax Act, 1961, Prevention of Money Laundering At, 2002, Prevention of Corruption Act, 1988 and or anyother zplicable laws enacted by the Government of india rom time to tine. The Petfolo Manager scommitted to complying vith all applicable anti-money laundering laws and regulations inal of ts operations Accordingly, the Portfolio Manager reserves the right t ejector refund or freeze the ‘account of the chet ifthe cent does not comply wth the internal policies of the Portfolio Manager or any of the Applicable Laws incuig the KYC quirements “True Bescon, The Marqus, rd Flor, No 19, Vital Maya Road, Bengaluru, Karnataka, nda 36000" ‘ww ruebeacon com | [email protected] | +81 9639-03202True Beacon 6 4, The Portfolo Manager shall aot be held liable in any manner for any claims arising whatsoever on account of freezing the account/feecionor refund the application et, ‘due to nos-complance with the provisions of any of the aforesaid regulations or ‘Applicable Laws. 5, Investors are requested to note that KYC is mandatory fr al ivesors. SBI vide circular no. MIRSD/SE/Ci-21/2011 dated 5 October 2011, and CRVMIRSD/ 11/2012 dated 5 September 2012, has mandated tht the uniform KYC form and supporting documents ‘all be used by all SBI vegstered intermediaries in respect ofa new clients from January 1, 2012: Further, SEBI vie cicular no, MaRSD/Cie23/2011 dated 2 December 2011, has developed a mechanism for centralization of te KYC records in the secures market to bring about uniformity Insecurites markets 5. Accordingly, KYC rgbtration Is being centralized through KYC Registration Agencies ‘egistere wth SEB, Thus, each Client has to undergo auniflorm KYC process only once inthe securties market andthe details woul be shaed with other intermediaries bythe YC Registration Agencies. Applications shal be able to be ejected if he Cents donot comply with the aforesaid KYC requirements, 7. As per the 2015 amendment to PML (Maintenance cf Records) Rules, 2005, every porting entity shal capture the KYC lformation for sharing withthe Central KYC ecorde Registry inthe manner mentionad inthe PAL [Uaintenance of Rear) Res, 2005, as per the KYC template for ndvidls’ fialued by ental Registy of Securitsation Asset Reconstruction and Security Interest Accordingly, the KYC template finalized by Central Registry of Securitisation Asset Reconstruction and Security Interest stall be used by the regstered intermethares ae Part | of account opening frm for Individuals, DETAILS OF INVESTMENTS IN THE SECURITIES OF RELATED PARTIES OF THE PORTFOLIO MANAGER Sr. [Investment [Name of the [Investment | Value af | Percentage [No | Approach, | asociate/related | amount (cost of | Iavestment as | of total AUM, any” | pany Investment) 25 | on last day of | ason last day fon last day of | the previous |of the the previous calendar | previous calendar tuarer (INRIn | calendar quarter (INR in| cores) ‘quarter crores) wit None NIL nt ha | lL - DETAILS OF THE DIVERSIFICATION POUCY OF THE PORTFOLIO MANAGER Please refer below foran overview ofthe dverscation poly and guidance on the maximum exposure in relation to assets under management ofthe Porttlo Manager: ww tubeacon com | nflo@@bueteacon com | 19% 96-630-03202True Beacon 1.10% at Secures level both for fied income and eauty) 2.20% at suer of Securities level (both for xed inconve and eauly) 2. 10% izsvance at Cent level Please refer below for guidance on fixed income duration: ature Term Shor Tem ies than yen ein Tem Tes thon Syn | vastor tem Tein yer Te dation ‘more than 5 yars Fan awd Tessin mente The guidance as suggested above may be altered based on Clan’ risk appetite and voltity requirements. However, uch alteration willbe subject toa witen consent from the Client Date: 12 Api 2003, 7.1 la Name: Me Richard Pate Place: Bengaluru Date: 12 Apri 2023, Designated Partner Speous "Name: Me Saransh Maheshwari Place: Bengaluru Date: 12 Apri'2028, “True Beacon, The Marquis, 2a Floor, No, 19, Vital Mallya Road, Bangaturu, Kamaink, Inia www tuebeacon com | nfo@truebeacon com | +01 96830-03202 "560004True Beacon Form Secures and Exchange Hoar of nda (Portotlo Manages} Regulations, 2020 (Regulation 22) ‘True Beacon Investment Advisors UP Address: The Marquis, 3 Flor, No.1, Vital Mallya Road, Bengluru ~S60 003 Telephone number: 9653903202 ‘malt weath [email protected] We confi tht: |) the Disclosure Document forwarded to the Secrtes and Exchange Board of India a accordance withthe SEB (Portolo Managers) Regulations 2020 and the guidelines and ‘iectives issued bythe Secures and Fschange Board finda from time to tne; 1) the azclosures made in the document ar tue, fair and adecuat to enable the investors to ‘make a well-formed decison regarding entrusting the management ofthe portfolio to us / Investment inthe Portfolio Manager; Iu) the Disclosure Document has ben duly certified on 12 Apri 2023 by Mr. PartikOharwal, 3 Proprietor of M/s POharival& Co, Chartered Accountants aving membership no. 245182 snd ofc a 45/3 Surveyor Steet, Bzavangud Bangalore S5000%, Krnatka India Pace: Bengaluru ‘Me. Saurabh Ohole- Principal Officer “Tue Bescon, The Margie, rd Floor, No 19, Vital Mala Rood, engalur, Kerataka India 36000" ‘aw rucbeacon com | info@hivebeacon com |¥81 96630-03202A pons Chartered Accountant CERTIFICATE 10 ‘TheParters, “Tre Beacon Investment Advisors LLP (Portfolio Manager’) ‘The Marquis 31 Foor, Na. 19, ‘Vital Mallya Roa, Bengaluru ~ 560001. ‘Subject: Certificate verifying that the disclosures made inthe Eselosure Document by the Portfolio Manager are tue, fai and adequate You have requested us to provide a certifiate on the Disclos.re document for Portfolio Management services (‘the Disclosure Document’) of True Beacon Investment Advisors LLP (‘the LLP"). We understand that the disclosure document isrequired tobe submitted to the Seeurites and Exchange Board of India (‘the SEB). 1. ‘The Porttio Manager olds reqistation with the Securities and xchange Hoard of nla (CSEBK) as a porto manager bearing registration no. IN2000007353. The Portola Manager has requested us to provide a certificate verfyng the disclosures made i the Aisciosure document offering portfolio management services (Disclosure Document”) to Prospective cients We understand that the disclosure documert required tobe submited to the SEBL under the SEBI (Portfolio Managers) Regulations, 2020 ("PM Regulations" 2. We declare thatthe Disclosure Document and compliance withthe PM Regulations and the ‘SEB Circular tiled ‘Guidelines for Portfolio Managers Issued by SEBI on 13 February 2020, isthe responsibilty of the management of the Poetfollo Manager: Our responsibly is limited to reporting in accordance with the Guldance note an Ait Reports and Cerifctes for Special Purposes, as revised from time to time, issued by the Institute of Chartered Accountants oa. 3. The process of certification did not involve us performing aut tests forthe purpose of expressing an opinion onthe fainess or acuracy of ny ofthe iaancal information or the ‘nancial statement taken asa whole We have not performed anaudit.the objective of which ‘would be the expression of an opinion on the financial statement, specified elements, ‘ccount r tems theteo forthe purpose ofthis certfiate.Asordingy, we da not exprese such opinion. 4 tncespec ofthe information given nthe Disclosure document, e state that: 2, Thelistof persons classified as Associates or group companies and list of elated parties are relied upon as provided bythe LLP. The Promoters and director's qualieatio, experience and ownership detalls 2s eclared by them and have been accepted without f-terverfiation Office Address: 45/2, 1.8Samaja Road, Surveyor Sree, Basavangudl, Bangalore 560004, Enall i [email protected] |Contact No: +S1 9742626575,