SEBI Registered Investment Advisor - Licence No : INA300002857

a) Risk Profiling
Risk profiling (source Finametrica) is a process for finding the level of investment risk for your client considering the risk required, risk capacity and risk tolerance, where, Risk required is the risk associated with the return required to achieve the client’s goals from the financial resources available, Risk capacity is the level of financial risk the client can afford to take, and Risk tolerance is the level of risk the client is comfortable with. Risk required and risk capacity are financial characteristics calculated using your financial planning software. Risk tolerance is a psychological characteristic which is best determined by way of a psychometric test.
Risk profiling requires each of these characteristics to be separately assessed so that they can be compared to one another. Risk capacity and risk tolerance both act separately as constraints on what your client might otherwise do to achieve their goals (risk required). It is unusual for a client to be able to achieve their goals from the resources available within both their risk capacity and risk tolerance. Where a mismatch between risk required, risk capacity and risk tolerance has been found, the advisor’s role is to guide the client through the trade-off decisions that are required to reach an optimal solution. The final step in the risk profiling process is to ensure that the client has realistic risk and return expectations so that the advisor can be given the clients properly informed consent to implement the investment strategy.
b) Suitability
Product Suitability is another criterion we have to look into before recommending any product for our clients. The Risk Profiler is one of the guiding forces which play a pivotal role in recommending the suitable product for the client. However at times we need to make the client understand that playing ultra safe or conservative in investments will not yield desired results and they have to stretch themselves. However, we can only recommend them when they are agreeable to the proposition.
c) Client disclosure
We have to disclose to our clients all material information and conflicts of interest which can affect our recommendations. However, as per SEBI RIA guidelines we always make it clear to our clients that they are under no obligation to do any investments or insurance through us or any of our sub brokers. Our portfolio portal also have a option from where the clients can always see what commission is getting paid to us.
d) Record Maintenance
We have to maintain necessary KYC documents of our clients for our own records as well as for the purpose of verification by designated authorities. Besides we have to keep track of all investment advice given by us in hardcopy or electronic format for future reference. We have decided to keep it in electronic format for transactions while maintaining in hardcopy as well as electronic for KYC documents.
e) Engagement Letter
The Engagement letter forms an integral part of our financial planning and investment planning services and all our responsibilities, duties, liabilities and services are categorically mentioned in the same. We have to also mention the conflicts of interest if any in our suggestions in the letter. The letter helps both parties to be on the same page about the expectations we can have from each other.
f) Investment Advice
As per the SEBI RIA Regulations 2013, we have segregated the Investment Advice and Execution departments and as part of the process we have an investment advice agreement also in place to have a clear understanding of the process to be followed on this count.
g) Review
Periodic review of the portfolios is very important for keeping the financial plan progress in check and also helps the client planner relationship to foster on the right note.
h) Redressal of client grievances

ANNEXURE-B

INFORMATION REGARDING INVESTOR GRIEVANCE REDRESSAL MECHANISM IN ACCORDANCE WITH SEBI CIRCULAR NO. CIR/MIRSD/3/2014 DATED 28TH AUGUST, 2014

Dear Investor,
In case of any grievance / complaint against the Intermediary :
➤ Please contact Compliance officer of the Intermediary (Subhabrata Ghosh, 364/26A, N.S.C. Bose Road. Kolkata: 700047) / email-id (subhabratag@stepaheadia.com) and Phone No.- +91 9831016350.
➤ You may also approach our Chairman (Mr. Uttam Kumar Sen) / email-id (uttams@stepaheadia.com ) and Phone No. +91 9007658230
➤ If not satisfied with the response of the intermediary you can lodge your grievances with SEBI at http://scores.gov.in or you may also write to any of the offices of SEBI. For any queries, feedback or assistance, please contact SEBI Office on Toll Free Helpline at 1800 22 7575 / 1800 266 7575.