1. Objective

Generational Capital, a unit of Satwik and Ritwik Ventures Pvt. Ltd. ("the Company"), operates as a Mutual Fund Distributor under AMFI Registration Number ARN-175193. This Policy sets out the mechanism through which the Company receives, records, escalates, and resolves grievances raised by investors/clients in connection with the mutual fund distribution and related services it provides, in line with the requirements of the Securities and Exchange Board of India (SEBI) and the Association of Mutual Funds in India (AMFI).

The objective of this Policy is to ensure that every investor grievance is acknowledged promptly, investigated fairly, and resolved within defined timelines, and that investors are made aware of their right to escalate unresolved grievances to the Asset Management Company (AMC), AMFI, and SEBI.

This Policy is effective from 1st February 2021 and has been approved by Mr. Satwik Jain, Founder of Satwik and Ritwik Ventures Pvt. Ltd.

2. Applicability & Scope

This Policy applies to all grievances raised by investors/clients relating to services rendered by the Company under ARN-175193, including but not limited to: transaction execution (purchase, redemption, switch, SIP/SWP/STP), KYC and account servicing, statements and reports, commission/brokerage disclosures, and the conduct of the Company's employees or authorised representatives.

Grievances relating to the investment performance, NAV computation, or internal operations of a mutual fund scheme itself fall within the domain of the concerned Asset Management Company (AMC) and its Registrar & Transfer Agent (RTA); the Company will assist the investor in routing such grievances to the correct AMC/RTA channel.

This Policy governs investor/client grievances. Internal employee grievances are separately addressed under the Company's HR Policy Manual.

3. Definitions

• "Grievance" or "Complaint" means any written or verbal expression of dissatisfaction by an investor/client relating to the services provided by the Company, including delay, deficiency, error, or unfair practice.
• "Investor" means any client who has invested or sought to invest in a mutual fund scheme or other permitted product through the Company.
• "GRO" means the Grievance Redressal Officer designated by the Company under this Policy.
• "SCORES" means the SEBI Complaints Redress System, the online platform maintained by SEBI at scores.sebi.gov.in for lodging complaints against SEBI-regulated entities.
• "ODR Portal" means the SEBI-prescribed Online Dispute Resolution platform (accessible via smartodr.in) for resolution of disputes in the securities market through conciliation and arbitration, where a grievance remains unresolved through SCORES.

4. Grievance Redressal Channels

Investors may lodge a grievance with the Company through any of the following channels:

• Email to the Company's designated grievance mailbox: ritwik@generationalcapital.in
• Telephone / helpline: +91 870 005 1127
• In writing, in person or by post, at the registered office: WeWork Berger Delhi One, Berger Tower, Floor 18B-104, Sector-16B, Noida - 201301
• Through the investor's relationship manager / empanelled representative of the Company

5. Escalation Matrix & Turnaround Time (TAT)

Grievances are handled in a structured, time-bound manner as set out below. If an investor is not satisfied with the resolution at any level, they may escalate to the next level.

Turnaround times at Levels 3 and 4 are prescribed directly by SEBI (SCORES 2.0, effective 1 April 2024, and the SEBI ODR mechanism) and are stated here for investor awareness; the Company does not control these timelines but will support/coordinate wherever required.

6. Grievance Redressal Officer (GRO)

The Company has designated the following person as its Grievance Redressal Officer, responsible for oversight of grievance handling, record-keeping, and regulatory reporting under this Policy:

Name

Ritwik Jain

Designation

Director

Email

ritwik@generationalcapital.in

Phone

+91 870 005 1127

7. Grievance Handling Process

1. Every grievance received (by email, phone, post, or in person) is logged in the Company's Grievance Register on the date of receipt, with a unique reference number.
2. An acknowledgement is sent to the investor within 3 working days, along with the reference number and expected resolution timeline.
3. The GRO investigates the grievance, coordinating with the relevant AMC/RTA where the matter is outside the Company's direct control.
4. A written resolution/response is sent to the investor within the timelines set out in Section 5.
5. If the investor is dissatisfied with the resolution, they are informed of their right to escalate to the concerned AMC's Investor Relations Officer, and thereafter to SEBI SCORES and the SEBI ODR Portal.
6. All grievances, whether resolved internally or escalated, are recorded and tracked through to closure.

8. Record-Keeping & Reporting

• The Company shall maintain a Grievance Register capturing: date of receipt, investor details, nature of grievance, action taken, resolution date, and escalation status (if any).
• Grievance records shall be preserved for a minimum of 5 years, or such longer period as may be prescribed by SEBI/AMFI from time to time.
• A periodic summary of grievances received and resolved shall be made available to AMFI/SEBI upon request, including during due-diligence audits or inspections.

9. Investor Awareness

The Company shall make investors aware, at the time of onboarding and through its website/client communication, of: (a) how to lodge a grievance with the Company; (b) the Company's GRO contact details; and (c) their right to escalate an unresolved grievance to SEBI via SCORES (scores.sebi.gov.in) and, thereafter, the SEBI ODR Portal (smartodr.in).

10. Policy Review

This Policy shall be reviewed at least annually, or earlier if required pursuant to a change in SEBI/AMFI regulations, and shall be updated accordingly with appropriate internal approval.