1. Introduction Section
Alchemy Investment Management LLP (Alchemy) strives to meet the long-term objectives of stakeholders through superior service, absolute transparency and executional efficiency. This Complaint Handling and Grievance Redressal Policy aims to ensure timely resolution of client complaints and continuous improvement in processes and fund management.
2. Policy objectives
The objective of the policy is:
• To create a platform for timely resolution of client complaints and queries
• To ensure rigor and seriousness in Client Management, by involving all stakeholders in reviewing all logged Complaints & their status
• Continuous enhancement & Improvement of processes, Fund Management & Fund offering
• To create Distributor awareness, so, they own the responsibility of reporting to us all Queries and Complains that come to them
• To create Client awareness, so they know how to connect with us directly or through the Distributor to log a query or compliant with us
3. Appointment of Compliant Redressal Appellate Officer (CRAO), Complaint Redressal Officer (CRO) and constitution of the Committee
• Any one of the Designated Partner shall be designated as Compliant Redressal Appellate Officer (CRAO) and the Compliance officer as Complaint Redressal Officer (CRO).
• The Grievance Redressal Committee, headed by the CRAO ensures fair, transparent, and professional handling of complaints.
• The Grievance Redressal Committee consists of CRAO, CRO, Group Head of Compliance and the Chief Executive Officer of parent company.
• CRO shall be responsible for handling of complaints received from its Clients or through Distributors.
• All Complaints will be placed before the Grievance Redressal Committee.
• The Grievance Redressal Committee shall examine and process the complaint in a fair, transparent, professional and impartial manner
4. Redressal Mechanism for Clients
If the Client has any concerns or wish to register a complaint, the Client can follow the below process:
Step 1 – Name, address and telephone number of the Complaint Redressal Officer who shall attend to the Client complaints are as follows:
Name: Mr. Rakesh Kar
Address: Unit No. 1120 A, 11th Floor, Signature, Block 13B, Zone 1, GIFT SEZ, GIFT City, Gandhinagar, Gujarat - 382355, India
Phone: (91-22) 6617 1717
Email: complaints@alchemyim.com
Step 2 - If the Client is not satisfied with the response received by following the Step (1) above then he/she may escalate the concern with all relevant details by sending an email to CRAO at escalations@alchemyim.com
Step 3 - If the resolution provided at Step (1) and then Step (2) does not meet Client's expectation, he/she may approach IFSC through email to grievance-redressal@ifsca.gov.in within 21 days from the receipt of the response.
It is to be noted that this policy shall be prominently disclosed on the website of Alchemy under the heading "Complaint Handling and Grievance Redressal" along with the name and contact details of the Complaint Redressal Officer and the Complaint Redressal Appellate Officer.
Detailed grievance redressal mechanism for employees to adhere is provided in Annexure A.
5. Timeline for responding to Clients
The Grievance Redressal Committee will endeavour to respond to all Client Complaints / Queries within 7 working days of receipt of compliant.
6. Ensuring Distributor escalates Complaints
• Whilst the Investment Manager will ensure that the Distributor agreement carries the clause on escalating of all Queries / complaints to the Investment Manager on an Ongoing Basis.
• Business development teams will ensure that this is re-iterated to all Distributor RMs in Fund launch forums & trainings.
• The Distributors would inform the list of Complaints that they would have received from their clients, that pertain to Alchemy as their Investment Manager.
7. Type of Clients, who could log in a Complaint
Direct Clients: These clients are sourced directly by Alchemy. The concerned person who receives the complaint escalates this to the Grievance Redressal Committee.
Distributor Clients: These clients are sourced by Distributors or Referral Partners engaged by the Investment Manager. On-boarding of these clients happen in either of the 2 ways:
• Direct Client: The Fund undertakes the KYC of the clients and has access to the clients. Complaints/Queries from such clients are handled as per the process applicable to direct clients is followed.
• Omnibus Route: The investment in the Fund is through the Omnibus/Pooled account of the Distributor. Under this route, the details of the underlying clients are not known to the Fund. It is primarily the responsibility of the Distributor to ensure that the complaints are resolved effectively. And Client Queries/complaints of such clients are generally routed through the Distributor.
If any Distributor client directly contacts the Investment Manager/ Fund, then the Investment Manager / Fund must bring this to the notice of the relevant distributor immediately, with a requirement that the distributor should keep Alchemy in copy for all communication with the clients.
The Distributor may seek support from the Investment Manager if required. However the Distributor must disclose facts of any compliant having a potential threat on the Investment Manager's reputation.
8. Classification & Scope of Complaints
For the purpose of this policy, Complaints that fall within this scope can be broadly classified as follows:-
• Acts involving inappropriate advice, misrepresentation or inadequate disclosure of information;
• Any complaints made to regulatory or official bodies or the press or media;
• Breach of any confidentiality obligations or misuse of client data;
• Acts involving fraud, dishonesty or other offences of a similar nature by any service providers;
• Other misconduct involving non-compliance with any regulatory requirement;
An indicative list of matters not considered as 'complaint':
• Anonymous complaints (except whistleblower complaints)
• Incomplete or un-specific complaints
• Allegations without supporting documents
• Suggestions or seeking guidance/explanation
• Complaints on matters not relating to the financial products or services provided by the Regulated Entity
• Complaints about any unregistered/ un-regulated activity
• References in the nature of seeking information or clarifications about financial products or services
• Any other matters as notified by the regulator from time to time
Further, Routine Queries are not considered complaints and shall not fall within the scope of the policy. The Investment Manger tracks such client queries to ensure that they are appropriately handled by the Fund. These queries includes:
• Fund related – including pricing, marketing materials, disclosures which are relating to basic product features and offering;
• Administration related – including data integrity, accuracy, timeliness of information or correspondences and operational services etc.;
• After sales services or facilities provided by Alchemy
4. Redressal Mechanism for Clients
If the Client has any concerns or wish to register a complaint, the Client can follow the below process:
Step 1 – Name, address and telephone number of the Complaint Redressal Officer who shall attend to the Client complaints are as follows:
Name: Mr. Rakesh Kar
Address: Unit No. 1120 A, 11th Floor, Signature, Block 13B, Zone 1, GIFT SEZ, GIFT City, Gandhinagar, Gujarat - 382355, India
Phone: (91-22) 6617 1717
Email: complaints@alchemyim.com
Step 2 - If the Client is not satisfied with the response received by following the Step (1) above then he/she may escalate the concern with all relevant details by sending an email to CRAO at escalations@alchemyim.com
Step 3 - If the resolution provided at Step (1) and then Step (2) does not meet Client's expectation, he/she may approach IFSC through email to grievance-redressal@ifsca.gov.in within 21 days from the receipt of the response.
It is to be noted that this policy shall be prominently disclosed on the website of Alchemy under the heading "Complaint Handling and Grievance Redressal" along with the name and contact details of the Complaint Redressal Officer and the Complaint Redressal Appellate Officer.
Detailed grievance redressal mechanism for employees to adhere is provided in Annexure A.
5. Timeline for responding to Clients
The Grievance Redressal Committee will endeavour to respond to all Client Complaints / Queries within 7 working days of receipt of compliant.
6. Ensuring Distributor escalates Complaints
• Whilst the Investment Manager will ensure that the Distributor agreement carries the clause on escalating of all Queries / complaints to the Investment Manager on an Ongoing Basis.
• Business development teams will ensure that this is re-iterated to all Distributor RMs in Fund launch forums & trainings.
• The Distributors would inform the list of Complaints that they would have received from their clients, that pertain to Alchemy as their Investment Manager.
7. Type of Clients, who could log in a Complaint
Direct Clients: These clients are sourced directly by Alchemy. The concerned person who receives the complaint escalates this to the Grievance Redressal Committee.
Distributor Clients: These clients are sourced by Distributors or Referral Partners engaged by the Investment Manager. On-boarding of these clients happen in either of the 2 ways:
• Direct Client: The Fund undertakes the KYC of the clients and has access to the clients. Complaints/Queries from such clients are handled as per the process applicable to direct clients is followed.
• Omnibus Route: The investment in the Fund is through the Omnibus/Pooled account of the Distributor. Under this route, the details of the underlying clients are not known to the Fund. It is primarily the responsibility of the Distributor to ensure that the complaints are resolved effectively. And Client Queries/complaints of such clients are generally routed through the Distributor.
If any Distributor client directly contacts the Investment Manager/ Fund, then the Investment Manager / Fund must bring this to the notice of the relevant distributor immediately, with a requirement that the distributor should keep Alchemy in copy for all communication with the clients.
The Distributor may seek support from the Investment Manager if required. However the Distributor must disclose facts of any compliant having a potential threat on the Investment Manager's reputation.
8. Classification & Scope of Complaints
For the purpose of this policy, Complaints that fall within this scope can be broadly classified as follows:-
• Acts involving inappropriate advice, misrepresentation or inadequate disclosure of information;
• Any complaints made to regulatory or official bodies or the press or media;
• Breach of any confidentiality obligations or misuse of client data;
• Acts involving fraud, dishonesty or other offences of a similar nature by any service providers;
• Other misconduct involving non-compliance with any regulatory requirement;
An indicative list of matters not considered as 'complaint':
• Anonymous complaints (except whistleblower complaints)
• Incomplete or un-specific complaints
• Allegations without supporting documents
• Suggestions or seeking guidance/explanation
• Complaints on matters not relating to the financial products or services provided by the Regulated Entity
• Complaints about any unregistered/ un-regulated activity
• References in the nature of seeking information or clarifications about financial products or services
• Any other matters as notified by the regulator from time to time
Further, Routine Queries are not considered complaints and shall not fall within the scope of the policy. The Investment Manger tracks such client queries to ensure that they are appropriately handled by the Fund. These queries includes:
• Fund related – including pricing, marketing materials, disclosures which are relating to basic product features and offering;
• Administration related – including data integrity, accuracy, timeliness of information or correspondences and operational services etc.;
• After sales services or facilities provided by Alchemy