KYC & Client Onboarding Policy for New Clients

Disclaimers

This policy establishes the standardized KYC verification and client onboarding procedures followed by ETHIX (ARN-66910), AMFI Registered Mutual Fund Distributor, in compliance with SEBI Mutual Fund Regulations, AMFI Code of Conduct, AMFI Master Circular for MFDs dated 14-January-2026, PMLA (Prevention of Money Laundering Act) Rules, and KYC/AML norms.

Client Onboarding Journey – Process Flow

KYC Document Checklist

Individual Investors

Non-Individual Investors

NRI Investors

PAN Card

Aadhaar Card

Address Proof

Recent Photograph

Bank Statement / Cancelled Cheque

FATCA/CRS Self-Declaration

In-Person Verification (IPV)

PAN of Entity

Certificate of Incorporation / Registration

Board Resolution / Authorisation Letter

List of Authorised Signatories

UBO (Ultimate Beneficial Owner) Details

Audited Financials (if applicable)

FATCA/CRS Declaration

KYC of all Directors/Partners/Trustees

PAN Card

Valid Passport with Visa

Overseas Address Proof

Indian Address Proof (if available)

Foreign Bank Account Details

Indian NRE/NRO Bank Account Details

FATCA/CRS Self-Declaration

PIS Permission Letter (if applicable)

Execution Only Transactions – Special Procedure

In cases where the investor independently selects a scheme without the recommendation of the distributor (Execution Only Transactions), ETHIX shall:

Document the transaction as “Execution Only” in the records.
If the scheme is not suitable for the investor’s documented risk profile, send a written communication (email or letter) to the investor clearly stating: “The scheme you have selected does not match your assessed risk profile. We do not recommend this investment. You are proceeding at your own risk.”
Obtain written acknowledgement from the investor confirming that the investment decision was made at their own discretion despite the unsuitability communication.
Maintain the unsuitability communication and investor acknowledgement in records.

Periodic Review Schedule

Review Activity	Frequency
Risk Profile Review	Annually, or upon any material change in investor’s financial circumstances, goals, or risk appetite
Portfolio Review	Semi-annually, or upon request by investor, or upon major market event
KYC Update	As per KRA requirements – typically when any personal details change (address, bank, contact)
Commission Disclosure Update	Quarterly, as per AMFI guidelines
Fund Selection List Review	Annually, with ad-hoc reviews triggered by regulatory changes or major market events

Risk Factors – Investments in Mutual Funds are subject to Market Risks. Read all scheme related documents carefully before investing. Mutual Fund Schemes do not assure or guarantee any returns. Past performances of any Mutual Fund Scheme may or may not be sustained in future. There is no guarantee that the investment objective of any suggested scheme shall be achieved. All existing and prospective investors are advised to check and evaluate the Exit loads and other cost structure (TER) applicable at the time of making the investment before finalizing on any investment decision for Mutual Funds schemes. We deal in Regular Plans only for Mutual Fund Schemes and earn a Trailing Commission on client investments. Disclosure For Commission earnings is made to clients at the time of investments. Option of Direct Plan for every Mutual Fund Scheme is available to investors offering advantage of lower expense ratio. We are not entitled to earn any commission on Direct plans. Hence we do not deal in Direct Plans.

AMFI Registered Mutual Fund Distributor (ARN-66910)
Sole Proprietorship of Mehran Felfeli
MF Distribution Validity: 09-Sept-2008 to 13-Mar-2029
Registered Office: Bizzbay Commercial Complex, Office 151, Off NIBM Road, Pune – 411048, Maharashtra
Email: mehran@ethix.net.in | Website: www.ethix.net.in

Transaction Platform: NSE Invest MF Platform | Backoffice: Investwell
Proprietor: Mehran Felfeli
Grievance Redressal Officer: Mehran Felfeli

Mutual fund investments are subject to market risks. Please read the scheme information and other related documents carefully before investing. Past performance is not indicative of future returns. Please consider your specific investment requirements before choosing a fund, or designing a portfolio that suits your needs. The Firm receives commission from Asset Management Companies / issuers for distribution of Mutual Fund products in Regular Plans, as permitted under SEBI and AMFI regulations. Such commissions may include trail or other permitted forms. No commission or fee is charged directly to investors for Mutual Fund or Mutual Fund distribution. ETHIX makes no warranties or representations, express or implied, on products offered through the platform of ETHIX. We provide incidental advisory services only. For investment advice, please consult a SEBI-registered Investment Adviser. It accepts no liability for any damages or losses, however caused, in connection with the use of, or on the reliance of its product or related services. Terms and conditions of the website are applicable.