Grievance Redressal Policy

OBJECTIVE

Neogentle Advisory Private Limited (“NAPL” / “the Company”), a SEBI-registered Investment Adviser, is committed to dealing with client queries, concerns, and grievances in a prompt, fair, and transparent manner. This Policy sets out the mechanism through which clients and prospective clients may raise grievances, the timelines within which NAPL will address them, and the escalation avenues available to clients under the SEBI (Investment Advisers) Regulations, 2013 and circulars issued thereunder, in case they remain dissatisfied with NAPL’s resolution.

REGULATORY BASIS

Regulation 20 and 21 of the SEBI (Investment Advisers) Regulations, 2013 – obligation to redress client grievances promptly and to maintain an adequate grievance redressal procedure.

SEBI Master Circular for Investment Advisers dated 06 February 2026 – Grievance Redressal / Escalation Matrix to be displayed by Investment Advisers, and Annexure C (Complaint data disclosure format).

SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/80 dated 02 June 2025 – Investor Charter (opens in a new tab) for Investment Advisers.

SEBI Circular No. SEBI/HO/OIAE/IGRD/CIR/P/2023/156 dated 20 September 2023 and Master Circular No. SEBI/HO/OIAE/OIAE_IAD-3/P/CIR/2023/195 dated 31 July 2023 (updated 28 December 2023) – SEBI Complaints Redress System (SCORES) (opens in a new tab) and Online Dispute Resolution (ODR) (opens in a new tab).

SCOPE

This Policy applies to all queries, concerns, and grievances raised by any client, prospective client, or user of NAPL’s advisory services, in relation to the investment advisory services rendered by NAPL, including but not limited to advice given, fees charged, disclosures made, and conduct of NAPL’s representatives.

GRIEVANCE REDRESSAL / ESCALATION MATRIX

In accordance with SEBI’s Master Circular, the following Escalation Matrix is displayed on NAPL’s website, mobile application (if any), and at NAPL’s office(s), and shall be brought to the notice of every client at the time of onboarding:

MODES FOR LODGING A COMPLAINT

A client may raise a query, concern, or grievance through any of the following channels:

Email: grievance@napl.one

Telephone: +91 98983 01556

In writing / post, to: D-523, Swati Clover, Shilaj Circle, SP Ring Road, Shilaj, Ahmedabad - 380059

In person, at NAPL’s office during working hours.

Through NAPL’s website grievance form, if made available.

INTERNAL ESCALATION PROCESS

Step 1: All queries, concerns, and grievances received through any of the above channels shall first be logged and addressed by the Compliance Officer.

Step 2: If the complainant remains dissatisfied with the Compliance Officer’s resolution, the matter shall be escalated to the Principal Officer for final internal review.

Acknowledgement: Every grievance shall be acknowledged within 2 Working Days of receipt, stating the reference number and expected timeline for resolution.

TIMELINE FOR REDRESSAL

NAPL shall redress every client grievance promptly, and in no case later than 21 (twenty-one) calendar days from the date of receipt of the grievance, in accordance with Regulation 20/21 of the SEBI (Investment Advisers) Regulations, 2013. This is a regulatory outer limit and not a target – NAPL shall endeavour to resolve grievances at the earliest opportunity, well within this period.

Where additional time is genuinely required to investigate a complex matter, the complainant shall be informed of the reason for the delay and the revised expected timeline; however, this communication does not extend the 21-calendar-day regulatory limit, and any grievance not resolved within that period shall be treated as a compliance escalation requiring the Principal Officer’s immediate attention.

ESCALATION TO SEBI (IF UNSATISFIED WITH NAPL’S RESOLUTION)

If the complainant is not satisfied with the resolution provided by NAPL, or does not receive a response within the timeline above, the complainant may escalate the grievance as follows:

Step 1 – SCORES: Lodge the grievance on SEBI’s SCORES 2.0 platform at https://scores.sebi.gov.in (opens in a new tab) (also available as the SCORES mobile app for Android and iOS). Complaints filed on SCORES undergo a two-level review – first by the Investment Adviser Administration and Supervisory Body (IAASB), then by SEBI.

Step 2 – Online Dispute Resolution (ODR): If still dissatisfied with the outcome of the SCORES complaint, the complainant may pursue resolution through the SMART ODR portal at https://smartodr.in (opens in a new tab) for online conciliation or arbitration.

Physical complaints: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (E), Mumbai – 400 051.

SEBI Toll-Free Helpline: 1800 22 7575 / 1800 266 7575

INVESTOR SAFEGUARDS

NAPL shall never ask a client for login credentials, passwords, or One-Time Passwords (OTPs) relating to the client’s trading account, demat account, or bank account. Clients must never share such information with anyone, including NAPL.

NAPL shall not execute or carry out any trade on a client’s behalf without the client’s specific and positive consent on every trade.

Clients are requested to keep their contact details (email ID and mobile number) updated with NAPL at all times.

DISCLOSURE AND TRANSPARENCY

This Policy and the Escalation Matrix in Section 4 shall be displayed prominently on NAPL’s website and mobile application (if any), and at NAPL’s office.

The Investor Charter for Investment Advisers (SEBI Circular dated 02 June 2025) shall be made available on NAPL’s website and provided to clients as part of the onboarding process.

NAPL shall register on SEBI’s SCORES platform to monitor and respond to any complaint filed against it.

NAPL shall publish, on its website and mobile application, monthly data on investor complaints (complaints received, resolved, and pending, by source) in the format prescribed under Annexure C of the SEBI Master Circular, by the 7th of the succeeding month.

HANDLING AND RECORDKEEPING OF COMPLAINTS

The Compliance Officer may seek any additional information or documents from the complainant reasonably required to investigate and resolve the grievance.

A written record shall be maintained of every grievance received, the date of receipt, the action taken, and the date and manner of resolution.

All grievance records and related correspondence shall be retained for a minimum of 5 (five) years, in line with SEBI’s record-retention requirements for Investment Advisers.

Grievances relating to a financial product (as distinct from NAPL’s advisory conduct) shall, where applicable, be directed to the regulator or entity responsible for that product.

REVIEW OF POLICY

This Policy shall be reviewed at least annually, and earlier if required by a change in applicable SEBI regulations or circulars, and shall be approved by the Principal Officer or the Board, as applicable, before any revised version is published.