Grievance Redressal Policy

POLICY ON HANDLING OF COMPLAINTS AND GRIEVANCE REDRESSAL

This policy aims to establish a robust, transparent and efficient mechanism for receiving, handling and redressing complaints and grievances of Customers.

For the purposes of this policy

Complaint / Grievance shall mean and include:

a written or verbal expression of dissatisfaction against the operation of the Scheme or its employees resulting from a potential damage or wrongdoing to a Customer or from a violation of IFSCA guidelines or related laws/regulations which may or may not request for a claim for compensation.

Allegations such as failure to disclose conflicts of interest, misrepresentations, etc. Such grievances may be regarding processing of drawdown transactions, distribution of units etc.

It does not include: -

• Anonymous complaints (except whistleblower complaints)
• Incomplete or un-specific complaints
• Allegations without supporting documents
• Suggestions or seeking guidance/explanation
• Complaints on matters not relating to the financial products or services provided by the Entity
• Complaints about any unregistered/ un-regulated activity
• References in the nature of seeking information or clarifications about financial products or service.
• Customer feedbacks, queries/clarifications;

Governing Body shall mean the Board of Directors of the Company

Costomer shall mean a person who engaged in a financial transaction or activity with the Entity and includes a person on whose behalf the person engaged in the transaction or activity, is acting;

Customers can lodge complaints or grievances to the designated email address giftcityco@integratedindia.in

Handling complaints and grievance redressal

On receipt of a complaint, Complaint Redressal Officer (“CRO”) of the Company shall make an assessment on the merits of the complaint.

Pursuant to assessment,

• In case of acceptance, the Company shall acknowledge acceptance of complaints, in writing, within 3 working days of receipt of the complaint.
• In case of non-acceptance, the Company shall inform the complainant within 5 working days along with reasons.

The Company shall examine and process the complaint in a fair, transparent and independent manner.

The Company shall ensure that the CRO has sufficient authority to resolve the complaint or has access to individuals with the necessary authority to be able to handle the complaint in a fair and impartial manner.

In case the CRO is or was involved in the conduct of the financial service about which the complaint has been made, the complaint will be handled by another officer designated by the Company in a fair and impartial manner.

The Company may ask for additional information from the complainant during processing of the complaint.

The Company shall dispose of complaints preferably within 15 days but ordinarily not more than 30 days of acceptance of complaint.

The Company may either resolve the complaint or reject the complaint.

In case of rejection of a complaint, the Company shall give reasons for rejection of the complaint, in writing.

Upon closure of the complaint, the Company will share the root cause analysis of the issue along with the closure details.

If the customer does not come back within 7 working days for reopening of the case, the complaint will be considered as closed.

Appeal mechanism

In case a complainant is not satisfied with the resolution provided by the Company or in case of rejection of complaint, the complainant may file an appeal within 21 days from the receipt of the decision from the CRO, before a Complaint Redressal Appellate Officer (“CRAO”) by sending an e-mail to giftcitypo@integratedindia.in.

The CRAO shall dispose of the appeal within a period of 30 days.

Where a complainant is not satisfied with the decision of the Company and has exhausted the appellate mechanism of the Company, he may file a complaint before the Authority through email to grievance-redressal@ifsca.gov.in preferably within 21 days from the receipt of the decision from the Company.

Note: In case of global access, following resources of the Exchange shall not be available to the customers:

• Rights of investors or investors protection
• Dispute resolution mechanism
• Investor grievance redressal mechanism

However, the complaints resolution mechanism as mentioned above, will be available with all clients.

Maintenance of Records

The entity shall maintain all records relating to handling of complaints, including the following

• Complaints received and processed;
• All correspondence exchanged between the Entity and the complainants;
• all information and documents examined and relied upon by the Entity while processing of the complaints;
• Outcome of the complaints;
• Reasons for rejection of complaints, if any
• Timelines for processing of complaints; and
• Data of all complaints handled by it

Record shall be maintained for at least six years from the date of disposal of complaint.

In case of any pending litigation or legal proceeding relating to the complaint, the records shall be maintained for the applicable period, after final disposal of the proceeding

Records of complaints, including correspondence, evidence, resolutions, and timelines, shall be maintained for at least six years or longer in case of ongoing litigation.

Records shall be maintained in an electronic retrieval system.

Reporting

The Entity shall submit reports on complaints and resolutions to IFSCA as required.

The Annual Report, if any, to be submitted to IFSCA shall include a section titled “Complaint Handling and Grievance Redressal”, presenting data on complaints received, resolved, rejected, and pending.

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