Grievance Redressal Policy

This Grievance Redressal Policy ("Policy") sets out the framework for handling complaints, disputes, and grievances arising in connection with transactions facilitated through the Indipe platform ("Platform") by its channel partners, distributors, intermediaries, or integrated entities ("Partner"). This Policy shall be read in conjunction with the applicable agreement executed between Indipe ("Company") and the Partner.

1. ROLE OF THE COMPANY

1.1. The Company operates as an AMFI-registered Mutual Fund Distributor and technology-enabled platform, facilitating mutual fund distribution activities and providing system infrastructure, APIs, and related technological support for transactions undertaken through the Platform, including coordination with the respective Asset Management Companies ("AMCs"), Registrar and Transfer Agents ("RTAs"), payment gateways, and other authorized entities, as applicable.
1.2. The Company does not provide investment advisory services and does not undertake investment decisions on behalf of investors. To the extent the Company facilitates mutual fund distribution through the Platform, its role shall be limited to the activities permitted under its applicable regulatory status and arrangements with AMCs, RTAs, Partners, and other relevant entities. The Company does not assume any fiduciary or advisory responsibility toward investors.
1.3. Accordingly, the Company shall not be treated as a primary point of contact for grievances relating to Partner-level servicing, conduct, or activities. Any communication received by the Company from investors, whether directly or indirectly, shall be handled in accordance with the nature of the grievance and applicable regulatory requirements. Where a grievance relates to the Company's own services, activities, or obligations, the Company shall address the same in accordance with applicable law and its applicable grievance redressal framework.
1.4. The Company's obligations are strictly limited to maintaining the operational integrity of its technology platform and providing the services and support within its applicable role, subject to applicable terms and conditions. Responsibility for Partner-level investor servicing, Partner conduct, and matters attributable to the Partner shall remain with the Partner. Matters relating to AMC/RTA processing, transaction execution, or other third-party functions shall be addressed with the relevant AMC/RTA or intermediary, as applicable.

2. PRIMARY RESPONSIBILITIES OF PARTNER

2.1. The Partner shall bear full, sole, and exclusive responsibility for the receipt, acknowledgment, handling, investigation, and resolution of all investor grievances, complaints, disputes, or queries arising out of or in connection with transactions initiated, facilitated, or executed through the Platform. This responsibility shall extend to all interactions with investors and shall include, without limitation:
1. 2.1.1. transaction failures, delays, processing errors, or discrepancies;
2. 2.1.2. incorrect, incomplete, or unauthorized transactions;
3. 2.1.3. redemption, payout, NAV-related, or settlement concerns;
4. 2.1.4. mis-selling, misrepresentation, unsuitable advice, or advisory-related complaints;
5. 2.1.5. KYC, onboarding, documentation, or compliance-related issues;
6. 2.1.6. communication gaps, service deficiencies, or operational lapses attributable to the Partner.
2.2. The Partner shall ensure that all grievances are acknowledged, tracked, and resolved in a timely, transparent, and fair manner, strictly in accordance with applicable SEBI regulations, AMFI guidelines, and the grievance redressal mechanisms prescribed by the relevant AMC(s) and RTA(s). The Partner shall maintain adequate internal systems, processes, and trained personnel to effectively manage and resolve such grievances.
2.3. The Partner shall remain solely accountable for the quality, accuracy, and timeliness of grievance resolution and shall ensure that no act or omission on its part results in regulatory non-compliance, investor harm, or reputational risk.

3. GRIEVANCE RESOLUTION FRAMEWORK

3.1. The Partner shall acknowledge all investor complaints within 48 (Forty Eight) hours of receipt.
3.2. The Partner shall use best efforts to resolve all complaints within the timelines prescribed under applicable law, regulatory requirements, and the grievance redressal mechanisms of the concerned AMC/RTA, as applicable.
3.3. Where resolution requires intervention from AMC/RTA or other intermediaries, the Partner shall coordinate directly with such entities and keep the investor informed of the status.

The Company shall not be responsible for tracking, escalating, or resolving such grievances.

4. ESCALATION MECHANISM

In the event a grievance is not resolved within the prescribed timelines, or where the nature of the complaint warrants higher-level intervention, the Partner shall, without delay and at its own responsibility:

4.1. escalate the matter to the relevant AMC and/or RTA strictly in accordance with their prescribed escalation matrix and grievance handling procedures;
4.2. ensure continuous follow-up with such AMC/RTA until the grievance is fully resolved, and maintain documented records of all communications and actions taken;
4.3. keep the investor duly informed of the status, progress, and expected timelines for resolution at all stages;
4.4. where required or in accordance with applicable regulatory requirements, guide and assist the investor in lodging a complaint with SEBI through the SCORES (SEBI Complaints Redress System) platform;
4.5. promptly comply with and respond to any regulatory directions, notices, queries, or proceedings initiated by SEBI, AMFI, or any other competent authority in relation to such grievance.

The Partner shall bear sole responsibility for managing and resolving all escalations and shall ensure adherence to all applicable regulatory timelines and requirements. The Company shall have no obligation to participate in, respond to, or assume any responsibility for such escalations, proceedings, or communications, except to the limited extent required under applicable law or where technical information is specifically requested.

5. EXCLUSION AND LIMITATION OF COMPANY LIABILITY

The Company shall not be liable or responsible, whether directly or indirectly, for:

5.1. the receipt, acknowledgment, handling, investigation, or resolution of any investor complaints or grievances to the extent such matters are attributable to the Partner;
5.2. any delay, deficiency, error, omission, or failure in grievance redressal by the Partner, AMC, RTA, or any third party involved in the transaction lifecycle;
5.3. any regulatory action, inquiry, penalty, sanction, or reputational impact arising from unresolved, delayed, or improperly handled grievances to the extent attributable to the Partner or any third party;
5.4. any claims, disputes, or losses arising out of mis-selling, misrepresentation, incorrect or unsuitable advice, or unauthorized transactions carried out by the Partner;
5.5. any inaccuracies, omissions, or failures in communication between the Partner and the investor;
5.6. any acts, omissions, negligence, or misconduct of the Partner or its representatives.

Nothing in this Policy shall exclude or limit any liability of the Company to the extent such exclusion or limitation is prohibited under applicable law or regulatory requirements.

6. COMPANY SUPPORT

The Company may, at its sole discretion and without any obligation, provide limited technical assistance to the Partner strictly in relation to data and system-level information available on the Platform. Such assistance may include:

6.1. providing system-generated logs, transaction references, timestamps, audit trails, or other technical data relevant to transactions processed through the Platform;
6.2. sharing transaction status updates as reflected in the Company's systems, without any independent verification or validation;
6.3. facilitating limited technical coordination, where necessary, between the Partner and relevant AMCs, RTAs, or other intermediaries solely for the purpose of data clarification;
6.4. assisting in identifying potential system-level issues, if any, that may have impacted transaction processing, without assuming responsibility for resolution.

All such assistance shall be provided on a best-efforts basis and subject to system availability, data retention policies, and applicable confidentiality obligations. The Company shall not be required to investigate, adjudicate, or resolve any grievance, nor shall it be obligated to engage directly with investors, regulatory authorities, or third parties in connection with such grievances.

For the avoidance of doubt, any support provided by the Company under this clause shall be strictly limited to technical facilitation and shall not be construed as grievance handling, dispute resolution, advisory services, or acceptance of any liability, responsibility, or obligation in relation to the underlying transaction or complaint.

7. RECORD KEEPING AND AUDIT

The Partner shall maintain complete, accurate, and up-to-date records of all complaints, communications, actions taken, resolutions, and supporting documentation, including timestamps and audit trails, for a minimum period as prescribed under applicable SEBI/AMFI regulations or any other applicable law, whichever is longer.

Such records shall be maintained in a secure and retrievable manner and shall be made available promptly upon request to regulatory authorities, AMCs/RTAs, or the Company. The Partner shall ensure that these records are sufficient to demonstrate full compliance with applicable grievance redressal requirements and shall cooperate fully with any audits, inspections, or inquiries conducted by regulatory authorities or the Company in relation to grievance handling.

8. REGULATORY COMPLIANCE

The Partner shall ensure compliance with all applicable grievance redressal requirements under:

SEBI (Mutual Funds) Regulations, 1996
SEBI circulars on investor grievance handling and SCORES
AMFI Code of Conduct and best practices
AMC and RTA-specific grievance handling procedures

The Company shall have no responsibility to ensure or monitor such compliance.

9. INDEMNITY

The Partner agrees to fully indemnify, defend, and hold harmless the Company, its affiliates, directors, officers, employees, and agents from and against any and all claims, demands, actions, proceedings, losses, damages, liabilities, penalties, costs, and expenses (including reasonable legal fees and expenses) arising out of or in connection with:

9.1. any failure, delay, or deficiency on the part of the Partner in handling, addressing, or resolving investor grievances;
9.2. any breach or non-compliance by the Partner with applicable SEBI regulations, AMFI guidelines, or any other regulatory requirements relating to grievance redressal;
9.3. any investor disputes, complaints, claims, or escalations attributable to the acts, omissions, negligence, misconduct, or misrepresentation of the Partner;
9.4. any regulatory inquiry, investigation, notice, or action initiated against the Company arising from or related to the Partner's handling of investor grievances;
9.5. any failure by the Partner to maintain adequate records, documentation, or audit trails in relation to investor complaints

This indemnity shall survive termination of the Partner's engagement with the Company and shall apply irrespective of whether such claims arise directly or indirectly from the Partner's conduct.

10. MODIFICATION

The Company reserves the right, at its sole and absolute discretion, to amend, modify, supplement, or replace any part of this Policy at any time, with or without prior notice to the Partner, to reflect changes in applicable laws, regulatory requirements, business practices, or operational needs. Any such modifications shall become effective immediately upon being published on the Platform or otherwise communicated to the Partner. It shall be the responsibility of the Partner to review this Policy periodically to stay informed of any updates. Continued access to or use of the Platform by the Partner after such modifications shall be deemed acceptance of the revised Policy, subject to the terms of the applicable agreement and applicable law.