Terms & Conditions

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Last reviewed: 12 October 2026

Last updated: 12 October 2026. These Terms & Conditions apply to the website, digital portals and distribution-support services provided by SERNET Financial Services Pvt. Ltd. (“SERNET”, “we”, “us”).

1. Acceptance & Applicable Documents

Please read these terms before using our services. Where agreement is required for an account, instruction or paid service, it must be obtained through the applicable process; merely visiting an informational page does not authorise a transaction, charge or marketing subscription. If you do not agree to terms applicable to a requested service, do not proceed with that service.

Read these terms with our Privacy Policy, Disclosures, Investor Charter and the relevant product-provider documents. These terms govern SERNET’s website and services; provider agreements govern their respective products. In a conflict, mandatory law prevails and product-specific terms apply to that product. These website terms do not amend a provider agreement.

2. Scope of SERNET’s Services

SERNET provides financial-product distribution and related facilitation and service support, within the scope of its applicable registrations and arrangements. Our exact regulatory capacity, registrations, remuneration and provider responsibilities are set out in Disclosures. Website access does not create a discretionary portfolio-management, brokerage or independent investment-advisory mandate, or authority for SERNET to operate your account.

3. Eligibility, Accounts & Authority

You must have legal capacity and authority for the service you request. Minor-related requests must be made by an authorised guardian under applicable product rules; an entity’s representative must have appropriate authority. Access from outside India does not mean a product is available or lawful in your jurisdiction. Eligibility remains subject to applicable law and provider requirements.

Give accurate, current information and notify us of relevant changes. Keep your account credentials secure, do not share passwords or OTPs, and promptly report suspected unauthorised access through our Support Portal. We may verify identity, authority and instructions before acting. Use of your credentials does not conclusively establish authorisation or waive your right to dispute unauthorised activity.

4. Acceptable Use

Do not impersonate another person, submit false or unlawful material, attempt unauthorised access, introduce malicious software, disrupt services or bypass security controls. Do not use our website for spam, fraud or unlawful transactions. Automated access, bulk extraction or republication that infringes rights, exposes personal information or materially disrupts the service is prohibited without permission. This does not prevent lawful search-engine indexing, accessibility tools or permitted personal use.

5. Information, Calculators & AI Outputs

Website articles, news, market data, calculators and AI-generated responses are general informational or educational resources. They are not a personalised recommendation, an offer to buy or sell, a verified transaction instruction or a promise of returns. Results depend on assumptions and available inputs; market data may be delayed, third-party material may be inaccurate and AI outputs may contain errors or omissions. Verify material information against official product documents and obtain appropriate professional advice where needed before acting.

We aim to keep information reasonably accurate but cannot warrant that every item is complete, current or suitable for your circumstances. These limitations do not reduce obligations applicable to an actual service provided by SERNET. Investor-facing suitability and review guidance is maintained in the Investor Charter.

6. Instructions & Transaction Acceptance

A website enquiry, chat response or support-ticket acknowledgement is not confirmation of investment, allotment, redemption, execution or receipt of funds by a provider. Instructions must use the approved process and remain subject to verification, complete documentation, applicable cut-off times, receipt of funds and acceptance by the relevant provider. Rely on the provider’s official confirmation and statements for transaction status.

SERNET may seek clarification or decline to transmit an incomplete, inconsistent, unauthorised or unlawful instruction. We do not guarantee acceptance, processing time, a particular price or NAV, or liquidity. We remain responsible for our own service obligations under applicable law; provider processing conditions do not excuse our failure to exercise the required care. Onboarding and payment-safety guidance is in the Investor Charter.

7. Charges & Separate Service Agreements

Any separate charge for a SERNET service must be disclosed, including applicable taxes and material cancellation or refund terms, and agreed before that service is provided. These terms alone do not authorise a charge or prescribe a blanket non-refundable fee. Product charges and expenses are governed by the relevant provider documents; distributor remuneration is maintained in Disclosures. A separately agreed service contract may contain additional terms, subject to applicable law.

8. External Platforms & Third-Party Content

Links, downloads and integrations may take you to independently operated provider websites, apps or services. Their own terms apply to your use of them. A link does not mean SERNET owns or controls that platform, guarantees its availability or endorses every statement on it. Third-party branding belongs to its owner.

SERNET is not responsible for independently operated services beyond its contractual or statutory obligations, but remains accountable for its own representations, reasonable care in services it undertakes and responsibilities that cannot lawfully be excluded. Data-processing practices are covered only in our Privacy Policy.

9. Availability, Maintenance & Events Beyond Control

Website and portal access may be interrupted by maintenance, network failures, provider outages or other events. We do not promise uninterrupted access or error-free operation. Where practicable, we will communicate material service interruptions and take reasonable steps to restore services. If an instruction is time-sensitive, contact us or the relevant provider through an approved alternative channel; a website outage does not extend a provider’s cut-off time.

Events genuinely beyond reasonable control may delay performance only to the extent they prevent it. This does not excuse avoidable failures, remove duties to mitigate disruption or override legal obligations.

10. Intellectual Property

SERNET’s name, branding and original website content are protected by applicable intellectual-property law. You may view material and retain reasonable copies for personal, non-commercial use, with notices intact. Commercial reproduction, modification, redistribution or use of our branding requires permission unless otherwise permitted by law or the relevant licence. Official forms and third-party documents remain subject to their owners’ terms. Do not imply SERNET’s endorsement or affiliation without authorisation. Submitting documents or information for a service does not transfer your or a third party’s ownership rights to SERNET; processing is governed by the Privacy Policy and applicable law.

11. Responsibility & Limits of Liability

To the extent permitted by applicable law, SERNET does not accept liability for indirect or consequential losses arising solely from use of general website information, or failures of independently operated platforms outside our control. Responsibility for any loss depends on the applicable duty, causation and the facts; this is not a blanket exclusion of liability or an arbitrary monetary cap.

Nothing in these terms excludes or limits liability for fraud, wilful misconduct, negligence or breach of duties where exclusion would be unlawful, or restricts mandatory investor, consumer, privacy or other statutory rights. You are responsible for loss attributable to your unlawful or unauthorised misuse, only to the extent established under applicable law. You are not required to indemnify SERNET for its own wrongdoing.

12. Restricting Access & Ending Services

We may restrict website or account access where reasonably necessary to address suspected fraud, security threats, unlawful use, a material breach or a legal direction. Restrictions should be proportionate; where lawful and practical, we will explain the reason and offer an opportunity to resolve it. Urgent protective action may precede notice.

Ending website access does not by itself cancel an investment, extinguish accrued rights, prevent lawful access to records or remove complaint and servicing rights. Product exit, redemption and transfer requests remain subject to the relevant provider’s rules. Personal-data requests remain governed by the Privacy Policy.

13. Governing Law, Disputes & Changes

These terms are governed by the laws of India. Courts, tribunals, consumer forums and other competent authorities have jurisdiction as determined by applicable law or a valid product/service agreement. These website terms do not impose mandatory arbitration or prevent access to statutory remedies. For complaints and applicable escalation channels, use Grievance Redressal; for other questions, use our contact page.

We may update these terms and will show the revised date here. Material changes affecting an ongoing SERNET service will be communicated through an appropriate channel, with notice or fresh consent where required. Changes apply prospectively and do not retrospectively remove accrued rights or replace agreed service terms without a lawful basis. If a provision is held unenforceable, the remaining provisions continue only to the extent lawful; failure to enforce a term does not waive it.

Privacy Policy

/legal?tab=privacy

Last reviewed: 12 October 2026

Updated: 12 October 2026.

1. Introduction

This policy explains how SERNET Financial Services Pvt. Ltd. handles personal information in connection with its website, portals and financial-product distribution services, subject to applicable Indian data-protection and other laws.

2. Information We Collect

Depending on your interaction, we may collect your name, contact details, profile information, enquiries, support messages and documents you submit. Product onboarding may require identification, KYC, tax-residency, bank and financial information. Job applications may include resumes and employment information. Website usage may generate device, browser, IP address and interaction data. Website assistant or calculator inputs may include your messages; do not enter passwords, OTPs, unnecessary identity-document numbers or confidential third-party information.

3. Purpose & Consent

Information is used to respond to requests, support onboarding and servicing, manage accounts and complaints, communicate service updates, maintain security and meet applicable legal obligations. Marketing preferences and consent are handled separately from necessary service communications. Where processing is based on consent, you may contact us to withdraw it; this may limit services dependent on that information.

4. Sharing with Product Providers

Where necessary for a requested service, information may be shared with the relevant AMC, registrar and transfer agent, portfolio manager or other authorised provider. Hosting, email, support and AI-service providers may process information for service delivery where the relevant feature is used. Only information necessary for the purpose should be shared; this does not authorise sale of personal data or unrelated use of KYC documents. Information may also be disclosed where required by law. Each external product provider’s privacy policy applies to its own processing.

5. Cookies, Analytics & External Links

Cookies, local storage and similar technologies may support sign-in, preferences, security and analytics. Non-essential analytics or marketing technologies require choices or consent where applicable; accepting website terms is not a substitute for that consent. You can manage storage through your browser, although restricting it may affect functionality. Links to partner platforms take you to independently operated services with their own privacy practices.

6. Security & Retention

We use reasonable safeguards and access controls appropriate to the information and service. No online system can guarantee absolute security. Records are retained as necessary for the service, applicable legal requirements and dispute handling; deletion requests may be subject to those obligations.

7. Your Requests & Rights

Subject to applicable law, you may request access to or correction of your information, deletion where permitted, withdrawal of consent and redressal of privacy concerns. Identity verification may be required before acting on a request. Do not send passwords, OTPs or unnecessary sensitive documents in email.

8. Children & International Processing

Minor-related investment requests must be handled by an authorised guardian under the product’s rules. Service providers may process information in other locations, subject to applicable legal restrictions and safeguards.

9. Privacy Contact & Updates

Submit privacy questions or requests through our contact page, identifying the request as a privacy matter. Include only information needed; verification may be required before disclosure or changes. For unresolved service complaints, use Grievance Redressal. Material changes will be dated on this page, with notice or renewed consent where required. Applicable statutory remedies remain available.

Policies & Procedures

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Last reviewed: 12 October 2026

1. Information Technology Policy

This policy governs technology, information protection and service continuity across SERNET’s distribution business, website, portals, business systems and authorised personnel.

Version: 1.0 · Approved for publication and effective: 12 October 2026 · Next scheduled review: by 12 October 2027

Download Information Technology Policy — Version 1.0 (PDF)

1. Purpose and policy status

SERNET Financial Services Private Limited (SERNET) shall govern its technology to protect the confidentiality, integrity and availability of investor and business information, support dependable distribution services and meet applicable legal, regulatory and contractual obligations.

Version 1.0 is approved for publication and effective from 12 October 2026. The next scheduled review is due by 12 October 2027. This policy sets governance requirements; its publication is not certification that every control has been implemented or independently audited.

2. Business and technology boundaries

SERNET acts as an AMFI-registered mutual fund distributor (ARN 35275; EUIN E025145) and APMI-registered PMS distributor (APRN 10097; EUIN E19955). Both registrations are valid until 28 October 2028. SERNET is not itself a stock broker, Research Analyst, Registered Investment Adviser or portfolio manager.

The policy applies to employees and authorised contractors or vendors accessing SERNET information. It covers the website, internal and client/partner portals, CRM, HR and support systems, business email, cloud services, domains, integrations, devices, records and backups under SERNET control.

Independent AMC, RTA, portfolio-manager, insurance and other product-provider platforms remain subject to their own operational and regulatory responsibilities. An external link or distribution relationship does not transfer their registrations or responsibilities to SERNET. Requirements applicable to a regulated portfolio manager shall not automatically be represented as SERNET distributor obligations.

3. Responsibility assignments

MD & CEO — Bhavesh A Vora: approve the policy, resources, material risk acceptance and time-bound exceptions. CTO — Akshat B Vora: technical owner, responsible for access, inventory, safeguards, monitoring, vendor technical review and recovery evidence.

Compliance Executive — Gaurav V Shah: compliance coordinator for applicability review, policy evidence, record-retention obligations and incident-reporting coordination. This does not appoint him as a statutory compliance officer or CERT-In point of contact without separate authorisation.

CHRO — Bhumika B Vora: coordinate joiner/mover/leaver notifications and training. Ops Manager — Triveni M Suthar: coordinate service continuity and provider escalation. Ops Executive — Arvind Mishra and RM — Shrey Patel: follow approved workflows and report service or security concerns. Formal notification contacts shall be documented and authorised separately.

4. Inventory and lifecycle management

The CTO or authorised delegate shall maintain an inventory of material systems, devices, domains, subscriptions and integrations. Each entry shall identify a business owner, purpose, data classification, criticality, dependencies, vendor, support status and recovery priority. Actual hosting, storage and log locations shall be verified rather than inferred from a provider name.

New services require business approval and proportionate technical, privacy and continuity assessment. On retirement, access and integrations shall be removed, required records preserved, and remaining information securely deleted or returned. Inventory reviews shall occur annually and after material changes.

5. Accounts, access and authentication

Access shall use individually assigned accounts, least privilege and role-based authorisation. Business owners approve requests; the CTO records provisioning and changes. Public website access must remain separate from access to investor, personnel and administrative records. User-editable profile information shall not determine administrative privileges.

CHRO shall promptly notify the CTO when employment, engagement or duties change. Departing users shall have access disabled at the end of authorised access, and immediately where a security risk requires it. Company devices, active sessions, recovery factors and shared-service access shall be reviewed during offboarding.

Privileged access shall be separately approved and reviewed quarterly; other business access shall be reviewed at least annually. These are SERNET review requirements, not a claim of completed reviews. Multi-factor authentication shall be required for privileged cloud, domain/DNS, business-email and administrative accounts wherever supported. Unsupported systems require documented compensating controls and a dated remediation plan.

Passwords shall be strong and unique. Passwords, OTPs, recovery codes and access tokens must not be shared. Secrets shall be kept in approved secure storage, not source code, documents or ordinary chat. Suspected compromised credentials shall be revoked or rotated promptly.

6. Devices, software and acceptable use

Company devices shall be recorded, maintained, patched according to risk and protected with supported software, screen locks and appropriate encryption or endpoint safeguards. Lost or stolen devices must be reported immediately upon discovery.

Personal-device business access requires written manager and CTO approval with defined security and data-removal conditions. Unauthorised software, credential sharing, bulk copying of investor information and personal storage of business records are prohibited. Devices shall be returned and business data securely removed before reassignment or disposal.

7. Privacy, confidentiality and data integrity

Investor, KYC, financial, employee and commercial information shall be classified and handled according to sensitivity. Collection, access, sharing and retention shall be limited to an authorised purpose and applicable consent, agreement or law. Sensitive documents shall use approved restricted channels rather than public or predictable download links.

SERNET shall apply proportionate access controls, secure transmission and storage safeguards, logging and controlled write access. Corrections and material changes to business records shall be traceable. Production information shall not be copied into development or testing without approval and appropriate minimisation or de-identification.

External disclosures shall be limited to the relevant authorised provider or service vendor. Information received from AMCs, RTAs and portfolio managers shall be used only for permitted distribution and servicing purposes. Privacy requests shall follow the published Privacy Policy and any applicable legal exceptions. Confidentiality obligations continue after engagement ends.

No control eliminates all risk. This policy shall not promise absolute security, guaranteed uptime or guaranteed prevention of fraud.

8. Vendors, cloud services and integrations

Material vendors shall be assessed before onboarding and at least annually for information access, security, service dependency, incident notification, subcontracting, continuity, data location, record export and exit arrangements. Contracts and operational arrangements shall address confidentiality and return or deletion of information where applicable.

Vendor privileges and integration credentials shall be restricted, recorded and removed when no longer required. The CTO and compliance coordinator shall establish evidence of the storage, processing and log-retention arrangements required by law. A provider-hosted service does not remove SERNET’s applicable responsibilities.

Independent product-provider applications shall be identified as such. SERNET shall coordinate service issues through their authorised channels without suggesting that SERNET manages their underlying investment, execution or custody systems.

9. AI, automation and communications

AI and automation may support approved informational or internal workflows but shall not be represented as regulated investment advice, independent research or assured investment outcomes. Client-facing financial or compliance content requires suitable human review.

Passwords, OTPs, access tokens and unnecessary identifiable KYC, financial or employee records shall not be submitted to unapproved AI services. Approved AI processing requires purpose limitation, vendor review and controls proportionate to the information involved.

Business email and domain changes shall be authorised and checked for service impact. Sender authentication and DNS changes shall be tested against every approved sending service. Suspicious messages and payment requests shall be independently verified through known channels.

10. Development, change and vulnerability management

Changes to applications, access rules, integrations, infrastructure and DNS shall identify the owner, purpose, impact, approval, testing and rollback arrangements. Changes affecting investor access or sensitive records shall include relevant business review.

Testing shall check both permitted and denied access and essential public services. Releases shall be recorded and monitored. Emergency fixes may proceed to contain a serious risk or restore service, with the reasons documented and retrospective review promptly arranged.

The CTO shall review security alerts and vulnerabilities, prioritise by severity and exposure, assign remediation owners and record verification. Risk-based target dates shall be maintained in an internal remediation register; overdue items require escalation or approved exceptions.

11. Monitoring, incident response and reporting

Critical applications, authentication, business email, domains, integrations and backup jobs shall have proportionate monitoring. Suspected compromise, data exposure, phishing, lost devices or material outages shall be reported immediately to the designated internal contact. Personnel shall preserve evidence and avoid unapproved deletion or investigation.

The incident owner shall record discovery time, scope, affected systems, containment, recovery and communications. The CTO and compliance coordinator shall assess legal reporting duties promptly. Where an incident is reportable under the applicable CERT-In directions, SERNET shall report it within six hours of noticing it or being brought to notice, using available information and supplementing it as permitted. Internal approval or completion of investigation must not delay a mandatory report.

A formally authorised point of contact and reporting channels shall be maintained as required. Notification to affected people, providers, authorities or other parties shall follow the applicable law and contractual duties. The published security contact is not automatically the statutory point of contact.

Material incidents shall have a post-incident review, corrective actions, responsible owners and closure evidence. An internal response procedure shall define escalation, evidence preservation and communications without exposing sensitive operational details publicly.

12. ICT logs and reliable timestamps

SERNET shall enable relevant ICT logs and retain them securely for a rolling minimum of 180 days within Indian jurisdiction as required by the applicable CERT-In directions, or longer where another applicable obligation requires. Access shall be restricted and logs protected against unauthorised alteration or deletion.

The CTO shall verify vendor support and the completeness of authentication, administrative, security and other relevant system logs; evidence of location and retention shall be maintained. ICT clocks shall follow applicable CERT-In time-synchronisation requirements using NPL/NIC servers or an appropriately traceable accurate time source as permitted. Current implementation must be verified before compliance is claimed.

13. Record retention and secure disposal

The compliance coordinator and business owners shall prepare a management-approved retention schedule for investor, transaction, KYC, consent, complaints, employee, vendor and audit records. Periods shall follow applicable legal, regulatory and contractual requirements; a single unverified retention period shall not be applied to every category.

The CTO shall implement storage, access, archival and disposal controls. Records subject to a complaint, investigation, litigation hold or regulatory request shall be preserved until authorised release. Disposal shall address relevant copies and backups according to the approved schedule and documented technical constraints.

14. Backups and restoration

Critical records and configurations shall have documented backup arrangements that identify coverage, frequency, retention, protection, responsible owner and restoration steps. The CTO shall monitor backup success and escalate failed or incomplete jobs.

A backup is not evidence of recoverability until restoration is tested. Restore tests shall occur at least annually and after material recovery changes; results shall record data-integrity checks, recovery duration, failures and remedial action.

Recovery time objectives and recovery point objectives shall be set separately for each critical service based on business impact, dependencies, vendor capability and demonstrated recovery results. Management approval is required. Recovery targets and backup frequencies shall be documented internally and validated before assurances are given.

15. Business continuity and provider dependency

The CTO and Ops Manager shall maintain a continuity procedure covering responsible people, alternative communications and work arrangements, provider contacts, restoration sequence, reconciliation and service validation. The procedure shall identify limitations where a third-party provider controls service restoration.

During an outage, investor requests shall be directed only through authorised provider channels. Staff shall not improvise transaction acceptance, promise provider processing times or bypass authentication and payment safeguards. Affected teams shall receive accurate status updates.

A continuity walkthrough or exercise shall occur at least annually. Findings shall have assigned owners and target dates, and the plan shall be updated following material changes or incidents.

16. Training and operational evidence

Employees and relevant contractors shall receive induction and periodic awareness on phishing, credential protection, investor confidentiality, approved data sharing and incident escalation. Roles with administrative or sensitive-data access shall receive appropriate additional guidance.

Evidence shall include approvals, inventory and access reviews, changes, vendor assessments, incidents, retention decisions, restoration tests, exercises and corrective actions. Evidence containing sensitive operational information shall remain restricted rather than be published with this policy.

17. Review, exceptions and accountability

The policy shall be reviewed at least annually and after a material business, technology, regulatory or incident-driven change. The CTO and compliance coordinator shall propose revisions for management approval and maintain version history and review evidence.

Exceptions shall identify the requirement, reason, scope, risk, compensating controls, owner and expiry or review date. Material exceptions require MD & CEO approval. An exception cannot waive a mandatory legal duty. Suspected policy breaches shall be investigated fairly and handled under applicable employment, contractual and legal procedures.

18. Related public policies and contact

This policy supplements, rather than replaces, SERNET’s Privacy Policy, Policies & Procedures, Terms & Conditions, Disclosures and Grievance Redressal. Wording and links shall be maintained consistently across those documents.

For public policy questions, contact compliance@sernetindia.com. Service concerns may also be raised through SERNET’s support portal and escalated under Grievance Redressal. Users must never send passwords, OTPs or access tokens with a report.

2. HR Policy — Sales & Operations

This policy covers recruitment, onboarding, appraisal, retention, employee wellbeing, exit and handover for SERNET’s Sales and Operations departments.

Version: 1.0 · Approved for publication and effective: 12 October 2026 · Next scheduled review: by 12 October 2027

Download HR Policy — Sales & Operations — Version 1.0 (PDF)

Purpose & accountability

1. Purpose, scope and status

SERNET Financial Services Private Limited adopts this HR Policy to support fair recruitment, accountable performance, employee development and orderly exits in its Sales and Operations departments. It covers employees in these departments; consultants, channel partners and outsourced personnel are governed by their contracts, with applicable confidentiality and conduct requirements.

Version 1.0 is approved for publication and effective from 12 October 2026. The next scheduled review is due by 12 October 2027. This policy sets requirements; publication does not certify implementation or independent audit of every process.

This policy supplements appointment letters, approved compensation and incentive plans, attendance and leave rules, the IT Policy and applicable law. Statutory rights take priority; contractual terms must not reduce statutory entitlements. This document does not create a fixed salary increase, incentive, employment guarantee or universal notice period.

2. Business boundaries

SERNET is an AMFI-registered mutual fund distributor (ARN 35275; EUIN E025145) and an APMI-registered PMS distributor (APRN 10097; EUIN E19955), both valid until 28 October 2028. It is not itself a stock broker, Research Analyst, Registered Investment Adviser or portfolio manager.

Sales and Operations personnel must work only within SERNET’s authorised distribution and service activities. They must not promise returns, claim advisory registrations, undertake discretionary portfolio decisions or imply that product-provider registrations belong to SERNET. Role-specific certifications and identifier requirements must be checked before regulated customer-facing duties are assigned.

3. Responsibilities

MD & CEO: approve workforce budgets, this policy, senior appointments and material exceptions. CHRO: policy owner; oversee recruitment, employment records, reviews, employee concerns and exit coordination. Department managers: define roles, coach staff, record performance and organise handovers.

Operations Manager: oversee service quality, allocation and continuity. Sales reporting authority: use the approved organisation chart; a separate Sales Head is not assumed. Compliance Executive: review conduct, distribution authorisations and relevant compliance concerns. CTO: provision, change and revoke access in coordination with HR. Responsibilities shall be documented through authorised internal assignments.

Recruitment & onboarding

4. Hiring approval and selection

Before recruitment, the department manager shall submit the business need, job description, reporting line, work location, employment type, required competencies and proposed compensation range to HR. Recruitment proceeds after approved headcount and budget authorisation.

HR shall use job-relevant selection criteria and a documented shortlist. Interviews shall assess skills and behaviour consistently, avoid irrelevant personal questions and provide reasonable accommodation where required. Referral or family relationships must be declared; conflicted interviewers or approvers shall not make the sole decision.

Sales assessments shall cover distribution knowledge, clear communication, ethical customer engagement, CRM discipline and ability to explain product risks without guarantees. Operations assessments shall cover documentation accuracy, service follow-up, record control, confidentiality and escalation judgement.

Reference, qualification and employment checks shall be proportionate, lawful and conducted with appropriate notice or consent. Collect only necessary candidate information and restrict access. Original identity or qualification documents must not be retained as security, and candidates shall not pay SERNET recruitment fees.

5. Offer, joining and probation

HR shall issue a written offer or appointment letter stating role, manager, compensation components, location, work arrangement, probation if applicable, notice terms and relevant policies. Probation and notice periods shall follow approved contractual terms consistent with applicable law. Material discrepancies in checks must be discussed fairly before a decision.

Onboarding shall include identity and employment documentation, payroll details through restricted channels, role training, policy acknowledgement, complaint channels and approved system access. HR and the manager shall verify required product certifications or permissions before customer-facing duties start.

A documented induction plan shall cover distribution boundaries, customer data, KYC/document handling, complaint escalation, IT security and departmental workflows. Access must be role-based; staff must never ask clients to share passwords or OTPs or move client funds through personal accounts.

Where probation applies, the manager shall provide feedback before its end. Confirmation, a lawful documented extension or separation shall be communicated in writing with reasons and required process. Completion of onboarding does not waive statutory employment rights.

Appraisal & development

6. Review cycle and fairness

The review cadence comprises a monthly coaching discussion, quarterly documented performance review and annual appraisal. Goals shall be agreed in writing at the start of the cycle and revisited when roles or workloads change. HR shall communicate the annual appraisal period through the approved internal calendar.

Reviews shall combine employee self-assessment, manager evidence and relevant service/compliance feedback. HR shall moderate inconsistent ratings and conflicts of interest. Assess work actually assigned and reasonably within the employee’s control, accounting fairly for approved leave, disability accommodation, market conditions and provider delays.

Use an approved five-level rating scale: needs significant improvement, developing, meets expectations, exceeds expectations and exceptional. Give specific examples and let employees record comments. A rating alone does not guarantee an increment, promotion or incentive payment.

7. Department-specific measures

Sales: suitable distribution engagement within authorised scope; quality of qualified enquiries and documented follow-ups; conversion and net business where relevant to the role; client retention and service; accurate risk/commission explanations; complaint handling; certifications, CRM records and teamwork. Never judge performance only by gross sales, assets or commissions.

Operations: documentation completeness and accuracy; turnaround against approved service targets; reconciliation and exception resolution where assigned; service backlog and follow-up; complaint escalation; record security, access discipline and process adherence; handover quality and cross-training. Do not penalise staff automatically for delays caused by external providers.

Compliance and customer protection are mandatory safeguards, not tradeable against commercial targets. Suspected misconduct must be examined fairly through the conduct process; an allegation is not an automatic finding. Numerical targets, metric weights and incentive formulae shall be set in approved internal scorecards, not prescribed in this public policy.

8. Improvement, progression and appeal

For performance gaps, agree a written improvement plan describing specific concerns, support or training, measurable expectations and a reasonable review period. Distinguish a skills gap from misconduct; no automatic dismissal follows a low rating.

Promotion and compensation decisions consider sustained performance, role scope, skills, internal fairness, approved budgets and applicable contractual commitments. HR shall communicate outcomes in writing. Employees may request an appraisal review through HR, with independent review where the original assessor has a conflict, without retaliation.

Retention & employee wellbeing

9. Development and continuity

SERNET shall support role-relevant learning, coaching, product knowledge and security/compliance awareness under an approved training plan. Sales learning shall emphasise distribution boundaries, risk communication and ethical servicing. Operations learning shall emphasise accurate documentation, exception resolution and resilient workflows.

Department managers shall document critical tasks and train a backup where feasible so customer service does not depend on one individual. Career discussions shall identify readiness for expanded duties; training or completion of a course does not automatically guarantee promotion.

Retention practices include periodic employee feedback, recognition of quality and teamwork, fair workload review and discussions about career needs. Retention offers or compensation adjustments require HR review and authorised approval, including checks for internal equity. No retention payment, benefit or frequency is guaranteed by this policy.

10. Compensation, leave and incentives

Fixed compensation, benefits and any variable pay shall be documented separately. Incentive plans must clearly define eligibility, calculation, payment timing, treatment of cancellations or corrections and departure conditions; material changes shall be communicated before they apply. Do not use incentives to encourage mis-selling, churning or concealment of complaints.

Attendance, working hours, holidays, leave, overtime where applicable and employee benefits shall follow approved employment terms and applicable law. HR must reconcile system settings with statutory requirements; software defaults do not establish legal entitlements or exemptions. Applicable provident fund, employee insurance, gratuity, maternity and other benefits must be assessed independently.

Lawful entitlements and earned wages cannot be removed simply because a target is missed, an employee resigns or a discretionary incentive is not approved. Any recovery or deduction must have a lawful basis and follow applicable limits and process.

11. Respect, concerns and support

SERNET shall maintain a respectful workplace without unlawful discrimination, harassment or retaliation. Employees may raise employment concerns with HR or the designated management authority, using an alternative independent reviewer when the concern involves that person. Complaints shall be handled promptly, fairly and with restricted access.

Sexual-harassment complaints shall follow the applicable statutory process and committee or Local Committee channel, not merely an ordinary manager complaint process. An Internal Committee shall be constituted where required by law. HR shall communicate the applicable statutory complaint channel to employees.

Managers shall review excessive workloads and customer pressure, support reasonable accommodations as required, and encourage reporting of errors or misconduct without retaliation. Confidentiality is protected to the extent possible, but cannot be promised absolutely when investigation or legal reporting requires disclosure.

Exit & handover

12. Resignation, separation and due process

Employees shall submit resignation in writing to their manager and HR. HR shall acknowledge it and confirm the intended last working day, applicable notice requirement and handover plan. Notice service, waiver or any lawful recovery must follow the employment contract and applicable law; this policy sets no universal 30-, 60- or 90-day requirement.

Employer-initiated separation, redundancy, retirement or end of a fixed-term engagement must follow the relevant law, contract and fair process. Where conduct is alleged, provide the required opportunity to respond and a proportionate decision through an authorised reviewer. Immediate access suspension for a security risk does not by itself determine employment termination.

HR shall document approved last working date and separation reason, restrict sensitive records and coordinate any required notices or benefits. Do not classify all resignations, poor performance cases or absence as misconduct.

13. Department-specific handover and access

Sales handover shall record assigned clients, enquiries, pending applications, service commitments and unresolved complaints in approved systems. The manager shall allocate a replacement contact and supervise necessary customer communication. Client relationships and records must not be copied to personal devices or used for unauthorised solicitation.

Operations handover shall record pending requests, document exceptions, deadlines, reconciliations where assigned, provider follow-ups and complaint escalations. A receiving employee and manager shall acknowledge the handover. Passwords must never be transferred; the CTO shall arrange individual access and ownership changes.

HR shall coordinate return of equipment, identity/access cards and other company assets. The CTO shall revoke access and active sessions at the end of authorised access, or earlier when justified, preserve required records and remove access from shared services. Confidentiality continues after departure, subject to lawful disclosures and reporting rights.

14. Settlement and exit records

HR and Accounts shall provide an itemised final settlement covering earned wages, eligible leave encashment, approved expenses, contractual variable pay where due, applicable statutory benefits and only lawful deductions. Different components may have different statutory deadlines; pay each within the applicable legal timeframe. Unresolved clearance or asset disputes must not unlawfully delay wages or statutory dues.

Any asset or notice-related dispute shall be documented and resolved separately through lawful process. No blanket forfeiture of salary or automatic deduction is authorised. Exit feedback is voluntary and shall not be a condition for payment of dues.

HR shall issue applicable service/separation documents and retain records securely for the justified legal or business period. Personnel files, exit interviews, customer allocations, settlement amounts and access checklists shall remain internal, not on the public website.

Governance & related policies

15. Conduct, controls and record privacy

Employees shall declare conflicts, avoid unauthorised gifts or benefits, use approved communications and keep accurate business records. Prohibit falsified documentation, unauthorised transactions, misleading sales statements and concealment of service failures. Customer complaints must be escalated under the published Grievance Redressal process.

Candidate, appraisal, compensation, disciplinary and exit information shall be available only to authorised personnel for a defined purpose. Maintain a documented retention schedule; allow lawful correction and access requests, and securely delete records when retention is no longer justified. Do not publish staff identity documents, private contact information or employment assessments.

Automation or AI may assist administration only with approved data handling and human review. It shall not be the sole basis for recruitment rejection, appraisal, disciplinary action or termination. Staff must not upload confidential personnel or customer information into unapproved tools.

16. Review, exceptions and acknowledgement

The CHRO shall coordinate an annual policy review and earlier review when law, business scope or employment arrangements change. The Compliance Executive and appropriate legal/payroll advisers shall verify statutory applicability; a small headcount or disabled software setting is not proof of exemption.

Material amendments and exceptions require authorised approval and documentation. No exception may waive statutory rights or authorised distribution boundaries. Staff shall acknowledge the approved policy and relevant changes; acknowledgement is not a waiver of employee rights.

The public policy shall describe the approved principles. Internal scorecards, compensation bands, interview notes, individual appraisals, disciplinary records and exit checklists shall remain controlled internal documents.

17. Related policies and enquiries

This policy complements SERNET’s Information Technology Policy, Privacy Policy, Terms & Conditions and Grievance Redressal arrangements. It does not replace employee contracts or statutory complaint channels. Employment concerns shall be raised with HR or the designated independent management authority; investor complaints shall use the published Grievance Redressal process.

For public policy enquiries, contact compliance@sernetindia.com. Do not send confidential personnel records, passwords or OTPs through public enquiry channels.

Disclosures

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Last reviewed: 15 October 2026

Registrations & Our Role

SERNET Financial Services Pvt. Ltd. acts as a distributor of financial products. SERNET is not a stock broker, Research Analyst (RA), Registered Investment Adviser (RIA) or portfolio manager. Partner registrations are not SERNET’s registrations.

• Mutual Fund Distribution — AMFI: ARN 35275 · EUIN E025145 · First registered: 10 February 2006 (confirmed by AMFI) · Valid until 28 October 2028.
• PMS Distribution — APMI: APRN 10097 · EUIN E19955 · First registered: 25 October 2025 (confirmed by APMI) · Valid until 28 October 2028.

Mutual fund schemes are offered by their respective AMCs. The relevant AMC, registrar (RTA), depository or portfolio manager handles applications, transactions and statements under its published service standards and statutory investor charter. Portfolio management, investment decisions, custody and reporting are the responsibility of the respective portfolio manager under its registration and client agreement. Stock-broker or depository service standards must not be attributed to SERNET’s distributor registrations. Verify registrations through AMFI and APMI.

Product Empanelments & Commission Documents

Mutual Funds

The following entries are supported by supplied provider documents or empanelment confirmations for SERNET. Empanelment confirmation and brokerage schedules are separate records: a schedule period is not an empanelment date, and an empanelment letter does not establish current commission rates. This is not an exhaustive list of SERNET’s empanelments. Dates and documents not supplied are marked accordingly; pending brokerage information does not imply zero commission.

Schedule scope: These documents relate to eligible Regular Plan transactions. Base commission excludes GST; GST-inclusive figures are separately shown in the originals. The dates describe transaction eligibility, not a guarantee of an unchanged rate throughout an investment’s life. Rates may change under provider terms and applicable rules; consult the source conditions before investing.

PMS & Other Products

SERNET’s APMI registration establishes its PMS distribution capacity; it does not by itself identify individual provider empanelments. Product-specific PMS, SIF, AIF, FD, bond and insurance provider entries and commission documents will be listed only after the relevant arrangements and documents are verified. Their absence here does not imply a zero commission or confirm distribution eligibility. Request current product-specific information from compliance@sernetindia.com.

Distributor Remuneration & Conflicts

Distributor remuneration may be paid by the applicable provider under its arrangement with SERNET. It is distinct from an independent investment-advisory fee and from investor charges or product returns.

Regular-plan mutual funds may involve trail commissions paid by the AMC under applicable arrangements. Remuneration may vary by provider, scheme, investment amount and period. Direct plans do not carry distributor commissions and may have different expenses from regular plans.

PMS distribution remuneration, where applicable, is governed by the relevant portfolio-manager arrangement and applicable rules. Review the manager’s disclosure document, fee schedule and client agreement; portfolio-manager fees and SERNET’s remuneration are distinct.

Differences in remuneration, incentives, commercial relationships or referral arrangements may create potential conflicts. Material conflicts must be disclosed for the relevant engagement; remuneration must not be represented as an investor return or hidden within a claim of independent advice. Ask for current provider/product remuneration details before deciding, particularly where a schedule is pending. Available schedules do not imply all schemes pay the same rate. Product-selection safeguards are maintained in the Investor Charter.

Product Risks & Provider Responsibilities

Mutual fund investments are subject to market risks. Read all scheme-related documents carefully. PMS, SIF, AIF and other securities investments involve market and other risks, including loss of capital. Past performance does not indicate future results. Registration or certification does not guarantee performance, endorsement or assured returns.

Company fixed deposits involve credit, interest-rate and liquidity risks. Bonds involve issuer credit, interest-rate and liquidity risks. Digital gold and silver involve price volatility and market risk. Insurance is a subject matter of solicitation; read the sales brochure, terms, exclusions and risk factors before concluding a sale.

Trading, insurance and other partner services are offered by their respective authorised providers. Verify the provider’s entity, registration, terms, fees and grievance contacts. See our provider network. Website information and tool limitations are in Terms & Conditions. Tax treatment depends on individual circumstances and may change. PMS strategies may involve concentration, leverage or derivatives where permitted; review the manager’s disclosure document and mandate. SIF/AIF eligibility, minimum investment, liquidity and redemption restrictions differ from ordinary mutual funds. Company deposits and bonds are not equivalent to guaranteed bank deposits; verify issuer terms and applicable protection.

For compliance queries, write to compliance@sernetindia.com. For complaints and product-specific escalation, see Grievance Redressal. See also the standalone Investor Charter.

Grievance Redressal

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Last reviewed: 12 October 2026

1. Level 1 — Raise Your Concern with SERNET

For concerns about SERNET’s distribution or service support, write to support@sernetindia.com or submit a request through our support portal. Include your name, contact details, product/provider, a description of the issue and relevant acknowledgement references. Attach only necessary evidence through the appropriate restricted channel; redact unrelated sensitive details. Never include passwords or OTPs. Retain the ticket or acknowledgement reference. SERNET should acknowledge, assess and track the concern and explain the outcome or referral. Applicable response requirements depend on the issue; no universal resolution period is promised.

2. Level 2 — Unresolved Complaint Escalation

If you remain dissatisfied with the Level 1 response, have not received a meaningful response, or the concern remains unresolved, write to complaint@sernetindia.com, quoting your earlier complaint or ticket reference. Resolution and escalation requirements depend on the issue and applicable rules.

3. Mutual Fund Product Complaints

For scheme transactions, statements, redemptions and other product-processing issues, contact the relevant AMC or registrar and transfer agent using its published grievance mechanism. Distribution-related concerns may also be raised through the appropriate AMFI channel where applicable.

4. PMS & Other Partner Complaints

For portfolio management, performance reporting, custody, manager fees or execution issues, first contact the relevant portfolio manager’s grievance officer. For trading or insurance products, use the respective broker’s or insurer’s complaint process. SERNET can assist with coordination but is not the broker, insurer or portfolio manager.

5. Applicable Regulatory Escalation

After approaching the concerned entity, eligible complaints against SEBI-regulated entities may be escalated through SEBI SCORES. Eligible disputes may be pursued through SMART ODR according to the platform’s scope and requirements. These channels are not automatically applicable to every complaint against a distributor. SCORES is for eligible securities-market complaints, not general banking or insurance matters; other complaints follow the relevant provider/regulator mechanism. Check current eligibility and procedures on the official platform. Internal escalation does not restrict applicable statutory remedies.

Keep copies of communications, acknowledgements and provider responses. For personal-information concerns, use the Privacy Policy.