Grievance Redressal Policy
Table of Contents
1. Background
Mosaic Asset Management Private Limited (hereinafter referred to as “Investment Manager”) is one of the sponsors to, and the investment manager of, the Mosaic Asset Management MultiYield Fund (“Fund”), a Category II Alternative Investment Fund (“AIF”) registered with the Securities and Exchange Board of India (“SEBI”) under the Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 (“AIF Regulations”) (SEBI Registration No. IN/AIF2/24-25/1597).
The Policy is applicable to all funds managed by the Investment Manager (collectively, “Mosaic Funds”) and their respective schemes, subject to the nature and requirements of each fund.
The Investment Manager shall be deemed to have adopted this Policy in respect of each scheme of the Mosaic Funds, severally and not jointly. No rights, responsibilities or liabilities of any scheme shall be attributed to any other scheme within the Mosaic Funds. This Policy shall be deemed to be a separate Policy for each scheme of the Mosaic Funds, and each reference herein to “Fund” shall be deemed to be a reference to each respective scheme severally and not jointly. The term “Fund” is used collectively herein for the sake of convenience only and shall in no way be deemed to impose or create any joint duties, obligations or liabilities among the schemes of the Mosaic Funds.
2. Objective
The objective of this Policy is to provide for an efficient and effective grievance redressal mechanism for investors. This Policy has been formulated taking into account the following objectives:
- Investors are treated fairly at all times;
- All complaints are dealt with efficiently and in a timely manner;
- Confidentiality is maintained at all times;
- Investors are informed of avenues to escalate their complaints/grievances; and
- The employees work in good faith and without prejudice, towards the interests of the Investors.
Further, as per the SEBI circular dated December 10, 2021 (“SEBI Circular”), the data on investor complaints received against AIFs and each of their schemes and redressal status thereof, is required to be disclosed by all AIFs as per the specified format. While implementing this Policy, each scheme of the respective Mosaic Funds shall also ensure compliance with the requirements of the SEBI Circular, including the requirement to maintain data on investor complaints as per the specified format, and compiling such data within 7 days from the end of each quarter.
3. Creating Awareness on Grievance Redressal Mechanism
The Investment Manager is required to create awareness amongst the investors regarding the following:
- Process for filing a complaint; and
- Process for escalation of complaint in case of delayed or no response.
4. Resolution Process
It may be noted that only the grievances received in written form will be considered under the grievance redressal mechanism. The Investor (including potential investor) shall address the complaint in the manner provided in Annexure A hereto.
A. Dhananjaya is designated as Grievance Redressal Officer under this Policy.
The Investment Manager shall respond to queries and requests within 2 (two) working days of receipt. Appropriate resolution shall be provided as soon as possible depending upon the nature of the query/request. In all cases the Investment Manager shall endeavor to resolve the complaint within 21 days from the date of complaint. Notwithstanding anything to the contrary contained herein, the Investment Manager shall comply with the grievance redressal mechanism and process as prescribed under SEBI Master Circular on the redressal of investor grievances through the SEBI Complaints Redress System (SCORES) Platform dated November 7, 2022 and SEBI Circular on Online Resolution of Disputes in the Indian Securities Market dated July 31, 2023, each as amended.
5. Changes in Policy
A review of this Policy would be carried out on an annual basis. Any material changes to this Policy that results in or could likely result in the obligations of the Investment Manager under this Policy, being diluted or becoming redundant, whether in letter or otherwise, shall be approved by the board of the Investment Manager (“Board”). An interim review can also be carried out to accommodate substantial changes, if any, on the regulatory and operating front after a prior intimation is provided to the Board.
6. Capitalised Terms
ANNEXURE A
1. Resolution Process
- An investor may submit a complaint or grievance by duly completing the ‘Investor Grievance Redressal Form’ in the form set-out in Schedule A hereto, and submitting the same to A.Dhananjaya, Grievance Redressal Officer at compliance@mosaicamc.com
OR
In the alternative, Investors may use SCORES platform to submit a complaint or grievance directly to Mosaic Asset Management Private Limited by opting for the ‘Direct Complaint’ option on the SCORES platform.
THEREAFTER
In the alternative, if the investor is still not satisfied with the outcome, he / she may initiate dispute resolution through the ODR (“Online Dispute Resolution”) portal at https://smartodr.in/login.
2. If the investor is not satisfied by the resolution provided, you may also consult the Grievance Redressal Officer, whose details are mentioned below:
Grievance Redressal Officer: A. Dhananjaya
Escalation Email: compliance@mosaicamc.com
Address: 44th Floor, Flat no. B-4404, Celestia Spaces, Tower B, TJ Road, Sewri, Mumbai, Maharashtra, India – 400015
3. A complaint submitted in any of the abovementioned modes, i.e., either by way of the Grievance Redressal Form or through ‘Direct Complaint’ on the SCORES platform, shall be redressed within 30 days without any intervention of SEBI, failing which, the complaint shall be registered on the SCORES platform.
4. Further, a one-time ‘Review’ option is also available on the SCORES platform, wherein, if the investor is not satisfied with the extent of redressal of grievance by Mosaic Asset Management Private Limited, he/she may opt for review of the extent of the redressal, within 15 days from the date of closure of the complaint on SCORES. Thereafter, the complaint shall be escalated to the supervising official of the dealing officer of SEBI.
2. Process for filing complaint through SCORES platform
- Investors who wish to lodge a complaint on SCORES are required to register themselves on www.scores.gov.in by clicking on “Register here” under the Investor Corner.
- Details like Name of the investor, Permanent Account Number (PAN), contact details, email ID, Aadhaar card number(optional), Central KYC (CKYC) ID (optional) etc. are required to be provided for effective communication and speedy redressal of the grievances.
- Upon successful registration, a unique user id and a password shall be generated and communicated through an acknowledgement email to the Investor.
- Investors may contact the Investor Associations (IAs) recognized by SEBI for any assistance in filing complaints on the SCORES platform. The list of IAs is available at www.sebi.gov.in. Investors may also seek assistance in filing complaints on SCORES from SEBIs toll free helpline number 1800 266 7575 or 1800 22 7575.
3. Process for filing complaint through ODR platform
Investors who wish to lodge a complaint on ODR are required to register themselves on https://smartodr.in/login.
Details like Name of the investor, Permanent Account Number (PAN), contact details, email ID, etc. are required to be provided for effective communication and speedy redressal of the grievances.
Upon successful registration, the investor will receive an email on the registered email address with a link to verify his/her account.
SCHEDULE A
Investor Grievance Form
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