right horizons disclosure statement

Pc:rtfolio ManagemeDeeSr rurderst;urrling. bertel r,:sn]is.

DISCTOSURE DO

Right Horizons Portfolio ManagePortfolio Managemen

Right Horizons Portfolio#6, Ground Floor, Arakere Village, 0pp. British Biologicals,

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UMENT

ent Private LimitedServices

ent Pvt. Ltd.Road, Bangalore -560 076.

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Form CSecurities & Exchange Board of India (Portfolio J Regulations 1993, Regulation 14

Name ofthe Portfolio Manager: Right Horizons Portfolio ent Pvt. Ltd

Regd, Office Address: #6, Ground FIoor, Arekere Village, British Biologicals, Bannerghatta

Road, Bangalore-560076.

Contact No: +91-080-65687503 to 518

Email: contactus@righthorizons-com

We confirm that:

The Disclosure Document forwarded to the & Exchange Board of India (SEBI) isin accordance with the SEBI (Portfolio Managers)directives issued by SEBI from time to time;

1993 and the euidelines and

The disclosures made in the document are true, fairmake a well informed decision regarding entrustinginvestment in the Portfolio Management Services;

adequate to enable the investors toe management of the portfolio to us/

The Disclosure Document has been duly by Chartered Accountant, Mr. K.R.Chartered Accountants, havingVenkkatesh, a Partner of M/s. Reddy and V

membership no. 211388 and office at # 7 /7,V.V. Puram, Bangalore - 560004.

Mansion, 2nd Floor, Diagonal Road,

For and on behalf of Right Horizons PortfolioAM

$ Wi-t - ' , ,P' , /U

,,?"' ,/Anil Reg6

Date: Feb 76,2017Place: Bangalore.

Pvt. Ltd

The Board of Directors,Right Horizons Portfolio Management Pvt. Ltd#6, Ground Floor, Arekere Village,Opp. British Biologicals, Bannerghatta Road,Bangalore-5 60076.

we have examined the Disclosure Document dated January t8, 2017 for portfolioManagement prepared in accordance with Regulation 14 of SEBI fportfolio Managers)Regulations, 1993 by Right Horizons Portfolio Management pvt Ltd., having its office at #6,Ground Floor, Arekere Village, Opp. British Biologicals, Bannerghatta Road, Bangalore-560076-

Based on our examination of attached Disclosure Document, audited annual accounts ofRight Horizons Portfolio Management Pvt. Ltd., and other relevant records and informatronfurnished by Management, we certify that the disclosures made in the attached DisclosureDocument for Portfolio Management are true, fair and adequate to enable the investors tomake a well informed decision.

We have relied on the representations given by the management about the penalties orlitigations against the Portfolio Manager mentioned in the disclosure document. We areunable to comment on the same.

This certificate has been issued to the Securities and Exchange Board of India for the solepurpose of certifl;ing the contents of the Disclosure Document for Portfolio Managementand should not be used or referred to for any other purpose without our prior writtenconsent.

For Reddv and Venkkatesh.Chartered AccountantsFirm Reg. No. 01

K.R. VenkkateshPartner Membership No. 211388

Right Horizons Portfolio#6, Cround Floor, Arakere Village, 0pp. British Biologicals,

Contact No.: +91-080-65687

iv. The name, phone number, e-mail address of th' the

DISCLOSURE DOCUMENT

[As per the requirement of Fifth Schedule ofBoard of India (Portfolio ManagersJ Regulation 1993J

i. The Disclosure Document has been filed withIndia along with the certificate in the pthe SEBI (Portfolio Managers) Regulations, 1,99

ii. The purpose ofthe Document is to providemanagement services in a manner to assistinformed decision for engaging Right HorizonsPortfolio Manager.

iii. The Disclosure Document contains theManager, required by an investor before inadvised to retain the document for future ref

Fund Manager is: Mr. Vinayak V Kanvinde,

Sharma & Mr. Gaurav Aggarwal.

Name of the Principal Officer: Mr. Anil Rego

Phone:91, 98455 66522

Email: [email protected]

Address: #6, Ground Floor, Arekere Village,

Road, Bangalore-56007 6.

t Pfi. Ltd.Road, Bangalore -560 076.

to 518

principal officer so designated by

on 14 of Securities and Exchange

Securities & Exchange Board offormat in terms of Regulation 14 of

tial information about the portfolioenable the investors in makins

ortfolio Management Pvt. Ltd. as a

information about the Portfolioand the investor may also be

Brian Mario Monteiro, Mr. Piyush

British Biologicals, Bannerghatta

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Table of Conte

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Disclaimer clause

Definitions

Description

Penalties, l it igation and convi

Services offered

Risk Factors

Client Representatio

The Financial Performance of Po olio Manager

Portfolio Performance on vario

Nature of Expenses

Accounting Policies

Investor Services

1) Disclaimer clause:The particulars given in this Document have been p

[Portfolio ManagersJ Regulations, 1993 and filed wibeen approved nor disapproved by SEBI nor has SEBIthe contents of the document. This document is notfurnished to you solely for your information and may nany other person.

in accordance with the SEBISEBI. This Document has neitherrtified the accuracy or adequacy ofpublic distribution and has been

t be reproduced or redistributed to

2) Definitions:Unless the context or meaning thereof otherwise , the following expressionsshallhave the meaning assigned to them hereunder respectiely:-[a] "Act" means the Securities and Exchange Board of In Actr992 {15 of L992).(b] "Agreement" means agreement between portfoliinclude all Schedules and Annexure attached thereto.

Manager and its Client and shall

[c] "Application" means the application made by theplace its funds and/or securities with the portfolio

ent to the Portfolio Manager toanager for Portfolio Management

Services. Upon execution of the Agreement by the po olio Manager, the Application shallbe deemed to form an integral part of the Agreementbetween the contents of the Apptication and theprovisions of the Agreement shall prevail.

rovided that in case of any conflictrovisions of the Agreement, the

[dJ "Assets" means (i) the Portfolio and/or [iiJ the F

[e) "Body Corporate" shall have the meaning assigned it in or under clause [7) of section2 ofthe Companies Act, 1956 [91of 1956J;[f] "Bank Account" means one or more accounts

Banks inmaintained

Portfolio Manager with any of the Scheduled Commasreement entered into with the Client.

and operated by theaccordance with the

[g] "Board" means the Securities and Exchange Boar! of India established under sub-section [1] ofSection 3 ofthe Securities and Exchange Birard of India Act.(hJ "Client" means the person who enters into an Agreeient with the Portfolio Manager formanaging its portfolio and /or funds.(i) "Custodian" means any person who carries on or prioposes to carry on the business ofproviding custodial services in accordance with the regqlations issued by SEBI from time totime.(j] "Depository Account" means one or more account oi accounts opened, maintained andoperated by the Portfolio Manager with any depqsitory or depository participantregistered under the SEBI (Depositories and Participan{sJ Regulations, l-996 in accordancewith the agreement entered into with the Client.

[k] "Discretionary Portfolio Management Services" ineans the portfolio managementselices rendered to the Client bv the Portfolio Manaser on the terms and conditionscontained in the agreement, where under the Portfolip Manager exercises any degree ofdiscretion in the investments or management ofasset$ ofthe Client.

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0] "Discretionary Portfolio Manager" means a Portfolio Manager who exercises or may,under a contract relating to portfolio. managemenl exercise any degree of discretion as tothe investments or management of the portfolio of securities or the funds of the Client, asthe case may be.

[m] "Documents" means this Disclosure Document.[n] "Financial Year" means the year starting from April L and ending on March 31 of thefollowing year.

[o] "Funds" means the monies managed by the Portfolio Manager on behalf of the Clientpursuant to Portfolio Investment Management Agreement and includes the monresmentioned in the Application, any further monies placed by the Client with the PortfolioManager for being managed pursuant to Portfolio Investment Management Agreement, theproceeds of the sale or other realization of the Portfolio and interest, dividend or othermonies arising from the Assets, so long as the same is managed by the Portfolio Manager.(pJ "Parties" means the Portfolio Manager and the Client; and "Party" shall be construedaccordingly.(q] "Person" includes any individual, partners in partnership, central or stategovernment, company, body corporate, cooperative society, corporation, trust, society,Hindu Undivided Family or any other body ofpersons, whether incorporated or not.(r] "Portfolio" means the Securities managed by the Portfolio Manager on behalf of theClient pursuant to the Portfolio Investment Management Agreement and includes anySecurities mentioned in the Application, any further Securities placed by the Client with thePortfolio Manager for being managed pursuant to the Portfolio Investment ManagementAgreement, Securities acquired by the Portfolio Manager through investment of Funds andbonus and rights shares or otherwise in respect of Securities forming part of the Portfolio,so long as the same is managed by the Portfolio Manager.(sJ "Portfolio Manager" shall have the same meaning as given in regulation 2(cb] of theSEBI [Portfolio ManagersJ Regulations, 1993 as amended from time to time.

[tJ "Principal Officer" means an employee of the Portfolio Manager who has beendesignated as such by the Portfol io Manager.

[u] "Regulations" means the Securities and Exchange Board ofRegulations, 1993, as may be amended from time to time.

[vJ "Scheduled Commercial Bank" means any bank included in

India [Portfolio Managers]

the second Schedule to theReserve Bank of lndia Act, 7934 (2 of 1934).

[wJ "SEBI" means the Securities and Exchange Board of lndia established under sub-section

[1-J of Section 3 ofthe SEBI Act.

[xJ "securities" includes: "securities" as defined under the Securities Contracts (RegulationJAct, 1956 as amended from time to time and includes:(i] Shares, scrips, stocks, bonds, debentures, debenture stock or other marketablesecurities of a like nature in or of any incorporated company or other body corporate;

Iii] Derivative;

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[iii] units or any other instrument issued by any cdllective investment scheme to theinvestors in such schemes;

[iv] Security receipt as defined in clause (g) of seltion 2 of the Securitization andReconstruction of Financial Assets and Enforcement of security Interest Ac! 2002;[vJ Units or any other such instrument issued to thd investors under any mutual fundscheme;

[vi] Government securities;

[viiJ Such other instruments as may be declared $y the central Government to besecurities;(viiil Rights or interest in securities;

[ixJ Exchange Traded Funds; and

[xJ Liquid Funds.Words and expressions used in this disclosure t and not expressly defined shal l beinterpreted according to their general meaning an usage. The definitions are not

of clarity and shall in addition beexhaustive. They have been included only for the pinterpreted according to their general meaning andassigned to them in regulations governing Portfolio M

e and shall also carry meanings

3) Description:iJ History Present Business and Background of the rtfolio Manager: Right HorizonsPortfolio Management Prt. Ltd. (RHPMPLI is a compan incorporated under the CompaniesAct, 1956 on May 27,20L0, having its Registered at #6, Ground Floor, ArekereVillage, Opp. British Biologicals, Bannerghatta Road,wholly owned subsidiary of Right Horizons Financial Se

Bangalore-560076. RHPMPL rs aces Pvt Ltd. IRHFSPLJ.

Right Horizons Portfolio Management Private Limited registered with SEBI as a PortfolioManager vides registrat ion no. INP 000004359 dated A 06,201-2under SEBI IPortfol ioManagersJ Regulations, 1993. This certificate has bee renewed for the period of 3 Yearvalid from 6/08/2015 to 05/08/2018 by SEBI. gran its approval for conduct of PMSbusiness to RHPMPL subject to compliance ofthe req ments specified bv SEBI.

ii] Promoters ofthe Portfolio Manager, Directors and

Promoters;

background:

Right Horizons Portfolio Management ServicesHorizons Financial services Pvt Ltd (RHFSPL).

RHFSPL.is a distribution arm of the Right Horizomanagement services. RHFSPL caters to a wide range o

t Services.

Ltd is promoted by Right

Group which provides wealth

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mer segments.

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For Individuals Right Horizons Group has a range of solutions that suits different customersegments from a Novice wanting t0 do tax planning to High Net worth Individuals. RH alsocaters to Non Resident customers for corporate customers. Right Horizons Group has aservice range including corporate Treasury, strategy, Mergers & Acquisition, Funding etc.Right Horizons Group has a unique corporate Help desk model where we help employeesof companies in tax saving and planning their investments. Right Horizons Groups objectiveis to deliver the best risk adjusted returns, which we achieve through a contrarianInvestment Style.

Directors and their background:

A) Mr. Anil RegoHe is a Chartered Financial Analyst & Holds an MBA with specialization in Financefrom ICFAI. He has worked in the Business Planning and Mergers & Acquisitionsfunctions with the finance department of Wipro Technologies, for 7 years. He hasdelivered Guest Lectures at premier Business-Schools. He has successfully practicedthe 'Contrarian' style of investing, for over a decade. He writes weekly / fortnightlycolumns in leading National and Regional publications like The Times of India,Money control, Mylris, Rediff.com, Financial Chronicle, Sakshi and Udayavani. Hisarticles, opinions and inputs are also featured in The Hindu Business Line, EconomicTimes, Dream Homes, The Wee[ among others.

B) Mrs. Rachna RegoShe finished her masters in Computer Applications. She has over 1-5 years'experience in leading IT Companies including Wipro and Infosys between 1994 -

2008. In her last role, she was handling the delivery of integration product practiceacross multiple accounts. She brings rich experience in handling the large teams, presales and quality/process. She has been a visiting faculty in Business Schools in theareas of Information Technology and Human Behaviors.

Group company information [i.e. information related to top 10 Group Companies/ firmsof the Portfolio Manager on turnover basis]

1-. Right Horizons Financial Services Pvt Ltd.2. Right Horizons Insurance Broking Services Pvt Ltd.3. Right Horizons Investment Advisory Pvt. Ltd.4. Fundz Street Financial Platform Pvt. Ltd.

Details of the services being offered:

Discretionary Services:

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under these services, the choice as well as the timings of the investment decisions restsolely with the Portfolio Manager and the portfolio Manager can exercise any degree ofdiscretion in the investments or management of assets of the client. The securitiesinvested/ disinvested by the Portfolio Manager for clients may differ from client toclient. The Portfolio Manager's decision (taken in good faithJ in deployment of theclient's fund's is absolute and final and can never be called in question or be open toreview at any time during the currency of the agieement or at any time thereafterexcept on the ground of fraud, malafide, conflict of interest or gross negligence. Thisright ofthe Portfolio Manager shall be exercised stribtly in accordance with the relevanrActs, Regulations, guidelines and notifications in force from time to time. periodicalstatements in respect to client's Portfolio shall be sent to the respective client.

Based on the Client's profile,the Portfolio of the Clients areInvestment Strategies:

overall investment objective and other relevant factors,at present managed under one or more of the following

1l Flexi Cap Portfolio Strategy2l Nifty Plus Portfolio Strategy3) Super Value Portfolio Strategy4l Multi Asset Portfolio Strategy5] Fixed Income Portfolio Strategy6l Capital Protection Portfolio Strategy7l Yield Multiplier- I Portfolio SrrategyB) Alliance Portfolio Strategy9) India Underserved Strategy101 India Undervalued Strategy

bl Non - Discretionary Serryices:Under the Non-Discretionary Portfolio Management Services, the portfolio of the Clientshall be managed in consultation with the Client. Uq der this service, the Assets will bemanaged as per the requirements of the Client after due consultation. The Client willhave complete discretion to decide on the investment (Stock Quantity and Price oramount]. The Portfolio Manager inter alia manages transaction execution, accounting,recording or corporate benefits, valuation and reporting aspects on behalf of the Client.

c] Advisory Services:Under these services, the Portfolio Manager provides only investment advice. Entry /exit timing, execution and settlement are solely the Client's responsibility.

4) Penalties, litigation and convietion details:

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Penalties, pending litigation or proceedings, findings of inspection or investigations forwhich action may have been taken or initiated by any regulatory authority: No penalties /directions have been issued by the sEBI under the SEBI Act or Regulations made thereunder relating to Portfolio Management Services. There are no pending material litigationsor legal proceedings, fihdings of inspections or investigations for which action has beentaken or initiated by any regulatory authority against the Portfolio Manager or itsDirectors, principal officers or employees or any person directly or indirectly connectedwith the Portfolio Manager under the SEBI Act and Regulations made there under relatingto Portfolio Management Services.

5) Services Offered:The Portfolio Manager manages the Assets of the Client using the following Strategies:

a) RH MULTIASSET PORTFOLIO:

Fund Manager: Mr. Vinayak Kanvinde

Multi Asset Portfolio is constructed across different asset class which offers betterand higher returns during different Macro Economic conditions. Multi AssetPortfolio goes a step further to even include Mutual Funds and Unlisted Securitiesand Nifty linked debentures.Features:

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T. All cases of penalties imposed by the Board or the directions issued by theBoard under the Act or Regulations made there under relating to PortfolioManagement Services.

N.A.

2. The nature of the penalty/d irect ion N.A.3 . Penalties imposed for any economic offence and/or for violation of any

securities law relating to Portfolio Management Services-N.A.

A Any pending material litigation/legal proceedings against the PortfolioManager/key personnel with separate disclosure regarding pendingcriminal cases, if anv

N.A.

5 . Any deficiency in the systems and operations of the Portfolio Managerobserved by the Board or any regulatory agency in relation to PortfolioManagement Services for which action may have been taken or initiated.

N.A,

6. Any enquiry/adjudication proceedings initiated by the Board against thePortfolio Manager or its directors, principal officer or employee or anyperson directly or indirectly connected with the Portfolio Manager or itsdirectors, principal officer or employee, under the Act or Regulations madethere under relating to Portfolio Management Services

N.A.

7.-

Multi Asset Portfolio is designed to suit the client needs and is quite dynamic innature i.e. as per the change in market condition changes will be made in assetallocation to keep it aligned with the client needs and risk levelThe portfolio has the ability to participate on opportunities across asset classesThough the investing strategy is built to suit for the client needs; investor,s withlong term horizons can invest and gain on the back of superior timing and assetallocation skills built for this oortfolio

b) RH FLEXTCAP PORTFOLIO:


A truly dynamic portfolio with the ability to participate into assets classes accordingto medium term macro-economic outlook. The portfolio could typically haveequities, commodities, derivatives and fixed income instruments, thoueh theoverwhelming portion could comprise of equitiesFeatures:o Flexicap is built to suit the macro situation prevailing at any point in time. This

means the portfolio composition changes depending upon how the prevailingcondition on the Global/lndian macro.

. The portfolio has the ability to participate on opportunities across asset classesand market caps and captures the upside in any asset class that might bepositioned to deliver

r The Flexicap Portfolio follows a contrarian style of investingr Though the investing strates/ is built to suit for the short/medium term;

investor's with long term horizons can invest and gain on the back of superiortiming and asset allocation skills built for this portfolio

RH NIFTY PLUS PORTFOLIO:

Fund Manager: Mr, Vinayak Kanvinde

The portfolio seeks to generate capital appreciation over a relatively 'medium-to-

long' term period. The idea of the portfolio is to stay above the benchmark at alltimes.Features:o Portfolio composition with typically 650/o in Nifty Index names with active

management of names and balance from broader index.. Typical portfolio holdings would have not more than 20-30 stocks and keeping

Niftv Index as benchmark.

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Overall Portfolio to have lower churned andrealignment churning would be higher

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only in case of large scale portfolio

d) RH FrXED TNCOME PORTFOLTO:


The primary investment object of the

r The list of securities would be a mix of diverbe durations, businesses and wouldallow for high portfolio flexibility.

and therefore

o We would endeavor to generate on a t basis superior risk adiustedreturns and capital appreciation by taking an active view on the markets in


This portfolio aims to provide inflation beating returns, and yet protect capital bycombining fixed income and equities to create a combination akin to a balancedportfolio.

Features:. Around 80o/o of portfolio would be invested into well rated medium duration

tradable securities over a period of time withl a medium to high level of liquidity.The securities would be dynamically marlaged and this would provide foradequate safety

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through investments in debt and money mar|<et instruments in order to maketimely interest payment. This is suited for investors with very low risk appetite.Features:. 0nly highly rated papers and investments into businesses with stability, safety

and high financial flexibility.o Care would be taken to see there is sufficie4t liquidiry in the securities that we

are investing into.r The duration of the debt portfolio would priinarily be managed with an attempt

to generate coupon income with minimum interest rate risk.o The securities would be dynamically ma4aged and this would provide for

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terms of interest rate movements or any othqr factor that may affect it.

RH CAPITAL PROTECTION PORTFOLIO:

r The list of securities would be a mix of diverse durations, businesses and wouldallow for high portfolio flexibility.

o Total term of the portfolio is recommended to be around 24 months andtherefore the duration ofthe portfolio would average less than 5 years.

' Equity portion of the portfolio would be limited to 20yo or lower at all timeso Equi$ exposure would be on ETF's and this would provide for dynamic

management, lower transaction costs and liquidiW.

0 RHSUPERVALUEPORTFOLTO:


This portfolio aims to provide inflation beating returns over a long duration, andcreate sustainable wealth over a long time frame.Features:. invest typically in the BSE 500 index. The stocks we invest are after doins

thorough primary research on the same.o A recommended holding horizon is over 36 months since the thesis play out in

smaller names could take longer than envisaged.. Benchmarked to the CNX MIDCAP index; this portfolio seeks to outperform its

benchmark. Typical holdings could range between 20-25 stocks from a variety of sectors to

protect downside and lower volatility; model portfolio would have no more than50 stocks,

g) RH YIELD MULTIPLIER PORTFOLIO:

Fund Managerl Mr. Brian Mario Monteiro

The primary investment obiect of the portfolio is to generate high income throughinvestments in secured securities from the real estate sector/projects includingdebt, mezzanine debt and preferred equity. This investment is suited for investorswith medium to high risk appetite.Features:r Yield multiplier predominantly invests in high yielding securities with

underlying returns of 1,7 - 24o/o with options to also use equity instrumentso Diversified across in different companies over the tenure ofthe fundo Payouts are reinvested by the fund manager which helps to compound the

returns & ensure that customer gets a larger corpus at the end. The fundmanager could choose to make payouts based on the market environment

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Low cost structure compared to similar funds

h) RH ALLTANCE PORTFOLIO:

Fund Manager: Mr, Vinayak Kanvinde

This portfolio aims to provide inflation beating returns over a long duration, andcreate sustainable wealth over a long time frame.Features:. Invest typically in the all asset class. The stocks we invest are after doinq

thorough primary research on the same.o A recommended holding horizon is over 24 months since the thesis play out in

smaller names could take longer than envisaged.r This portfolio is benchmarked to Hybrid indices based on option chosen and

aims to beat the index in the long duration time frames. We have benchmarkedcurrently with NSE Quality 30 Index.

. One time Setup fees and competitive annual fee provides for profit retention bythe investor

i) RH TNDIA UNDERSERVED PORTFOLIO:

Fund Manager: Mr. Piyush Sharma

This portfolio aims to provide inflation beating returns over a long duration, andcreate sustainable wealth over a lons time frame.Features:o Invest typically in the all asset class. The stocks we invest are after doing

thorough primary research on the same.. A recommended holding horizon is over 36 months since the thesis play out in

smaller names could take longer than envisaged.o This portfolio is benchmarked to CNX Nifty Index.o One time Setup fees and competitive annual fee provides for profit retention by

the investor

RH INDIA UNDERVALUED PORTFOLIO:

Fund Manager: Mr. Gaurav Aggarwal

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This portfolio aims to provide inflation beating returns over a long duration, andcreate sustainable wealth over a long time frame.Features:

o Invest typically in the all asset class. The stocks we invest are after doingthorough primary research on the same.

. A recommended holding horizon is over 36 months since the thesis play out insmaller names could take longer than envisaged.

o This portfolio is benchmarked to CNX Nifty Index.o one time setup fees and competitive annual fee provides for profit retention by

the investor

The Portfolio Manager may design and develop various series keeping in mind marketconditions and may be customized for Client's specific need/ profile. The Portfolio in allcases will be guided strictly by the relevant guidelines, Acts, Rules, Regulations, andnotifications prevailing in force from time to time. The instrument may be principalprotected or non-principal protected, which may have fixed or variable pay-offs. Theinvestment objective of the Portfolio Manager shall be preservation and growth of capitaland at the same time endeavor to reduce the risk of capital loss. However, while theaforesaid is the objective, it needs to be reiterated that there can be no assurance and/orguarantee of such growth or even as regards preservation of capital or of there being nocapital loss. The amount invested by the clients under tfis strategy may be subject to a lockin period as detailed in the Schedule to the agreement between the Client and the PortfolioManager. All the above mentioned strategies are used under the discretionary portfoliomanagement services as per the Regulations specified by SEBI.

The main features under Discretionary Portfolio Management Services are:

Investment under Portfolio Management Services will be only as per the SEBI pMSRegulat ionsL993The uninvested amounts forming part ofthe Client's Assets may at the discretion ofthe Portfolio Manager be held in cash or deployed in Liquid fund schemes, ExchangeTraded Index Funds, debt oriented schemes of Mutual funds, Gilt schemes, Bankdeposits and other short term avenues for Investment.The Portfolio Manager, with the consent of the Client, may lend the securitiesthrough an Approved Intermediary for interest.The Portfolio Manager will not invest any of the funds of the Client in the shares,mutual funds, debt, deposits and other financial instruments of group companies ofthe Portfolio Manager.

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F Customers will also be provided with periodic Valuation report, quarterlyperformance report, Periodic transaction statement (if anyJ, and euarterlytransaction statements.

F Apart from Discretionary Portfolio Management Services, the Portfolio Manager alsooffers Non-Discretionary Portfolio Management Seruices wherein the choice as wellas the timings of the investment decisions rest solely with the Client. The PortfolioManager manages the Assets ofthe Client in accordance with the directions given bythe Client. Further the Portfolio Manager also offers Advisory Pry Portfolio ManagementServices wherein the Portfolio Manager only renders investment advice to the Clientin respect of securities. Discretion to execute the transactions and responsibility forexecution/ settlement of the transactions lies solely with the Client.

) Minimum Portfolio Size: Rs. 25 lakhs or any amount not less than the statutoryminimum as may be specified by the Portfolio Manager from time to time.

6) Risk Factors:The investments made in securities are subject to market risk and Following are the riskfactors as perceived by management:Investment in equities, derivatives and mutual funds and Exchange Traded Index Funds aresubiect to market risks and there is no assurance or guarantee that the objective ofinvestments will be achieved.As with any investment in securities, the Net Asset Value of the portfolio can go up or downdepending upon the factors and forces affecting the capital markets.The performance of the portfolio may be affected by changes in Government policies,general levels of interest rates and risks associated with trading volumes, liquidity andsettlement systems in equity and debt markets.The past performance of the Portfolio Manager does not indicate its future performance.Investors are not being offered any guaranteed returns.The performance of the Assets of the Client may be adversely affected by the performanceof individual securities, changes in the market place and industry specific and macro-economic factors. In case of real estate funds there are risk inherent to the Real estaterelated Business such as dispute on title, availability ofraw materials, adverse Governmentpolicies, project location, macro and micro economic condition etc., though reasonable careis taken to address this risk. The investment strategies are given different names forconvenience purpose and the names of the Strategies do not in any manner indicate theirprospects or returns.Investments in debt instruments and other fixed income securities are subject to defaultrisk, liquidity risk and interest rate risk. Interest rate risk results from changes in demandand supply for money and other macroeconomic factors and creates price changes in the

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I 5

value of the debt instruments. consequently, the Net Asset value of the portfolio may besubject to fluctuation.

Investments in debt instruments are subject to reinvestment risks as interest ratesprevailing on interest amount or maturity due dates may differ from the original coupon ofthe bond, which might result in the proceeds being invested at a lower rate.The Portfolio Manager may invest in non-publicly offered debt securities and unlistedequities. This may expose the Client's portfolio to liquidity risks.Engaging in securities lending is subject to risks related to fluctuations in collateral value/settlement/ liquidity/ counter parfy.The Portfolio Manager may use derivatives instruments like index futures, stock futuresand options contracts, warrants, convertible securities, swap agreements or any otherderivative instruments for the purpose of hedging and portfolio balancing as permittedunder the Regulations and guidelines. Usage of derivatives will expose the Portfolio tocertain risks inherent to such derivatives as and when the Portfolio Manager deals in thederivatives market on behalf of the Clien! there are risk factors and issues concernins theuse of derivatives that investors should understand.Derivative products are specialized instruments that require investment techniques andrisk analyses different from those associated with stocks and bonds. The use ofa derivativerequires an understanding not only of the underlying instrument but of the derivativeitself.Derivatives require the maintenance of adequate controls to monitor the transactionsentered into, the ability to assess the risk that a derivative adds to the portfolio and theability to forecast price or interest rate movements correctly. There is the possibility that aloss may be sustained by the portfolio as a result of the failure of another party (usuallyreferred to as the "counter party") to comply with the terms of the derivatives contract.Other risks in using derivatives include the risk of mispricing or improper valuation ofderivatives and the inability of derivatives to correlate perfectly with underlying assers,rates and indices. Thus, derivatives are highly leveraged instruments. Even a small pricemovement in the underlying security could have a large impact on their value.There are inherent risks arising out of investment objectives, investment strategy, assetallocation and non-diversification of portfolio.The Net Asset Value may be affected by changes in settlement periods and transferprocedures.7) Potential Conflict of interest:a] Fund Managers are allowed to have personal investments into the funds ofthe portfolioManager. However, they are following principal of arms-length and treated on par with anyother customer of the portfolio manager.bJ Fund managers abide by the code of conduct which allows them to manage off shorefunds if any. Subject to, their abiding the code of conduct not to allow these funds to be withconflict of interest against portfolio Manager's funds.

I - -

lHort l ( ) l lo v lani lgHl l rI let! undet5mrtlnrs bertsf f ,rs{ttr.

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14

c) Other Group entities of the portfolio manager undertake distribution services. Theportfolio manager may avail services from these entities at on arms-length basis.

7) CIient Representation:a] Details ofclient's accounts activated:SN Category of clients Total No. of

clients (portfolio-wisecummulative)

Funds managed(Rs. Crores)

Discretionary/Non-DiscretionaryIif available)

Associates /groupcompanies (Last 3vearsl

NIL NIL

Others: {Last 3 vears)20t2-13 3 INR 1 crore Discretionarv2013-t4 158 INR 68.26 crore Discretionarv2074-t5 315 INR 117,54 crore Discretionary2015-L6 458 INR155.0789

croreDiscretionary

20t5-t6 1 INR 0.50 crore Advisory2016-17 (Halfyear) 507 rNR184.094

croreDiscretionary

2016-17 fHalfvear) 1 INR 0,50 crore Advisory

"Funds Managed" indicates market value of Assets under Management. The above figuresare given in compliance with amendment to the SEBI fPortfolio ManagersJ Regulatrons,1993 dated August 1-1,2008.

rtecf"lTR In *:*,y,r*iiser'|1e"f

bJ Key Management Personnel [Portfolio Management Services):

Anil Rego CEO and Principal Officer

Rachna Rego Compliance Officer

Vinayak Kanvinde VP - Fund Manager

Piyush Sharma Fund Manager

Brian Mario Monteiro Fund Manager

Gaurav Aggarwal Fund Manager

t )

Transactions with related parties for the period till pnded 3oth sep 2016 (Amount inRupees)

nik horiaoir PortnoEo fiborslrE ir Prhre Urir.d$6,&dfrlrli RodAr||r+E€af,lrEfiE{tr

norEt FgRia$Ea f4Rt {F psncT

f,lbtrd F.rf,, trrr8 Etio&5

Sis.r.E|J;|a ar.!9,1ir!d 4..4.6$r"riog St:ndrrd 1* -gdrtrd F:rty g&*oerxdz- ir:ic&lbar5 -

r, $!!r!5 df rElst Frrshr :$d d.lcrwoi af rer{i&rrhip s;*! rit. t..rft

glrE6!d.& l{s,r rnrfirBEri3l Fcrlor"lel AaAfrrrcGf,r6oSiru*t*r, thr..bntid.r & l{ry rnxragcri{ per:orlracl. Rrrll'}r BlEotioldhg..a$Frrll *igfrt flori.Brl! Fnjmdd 5cr-rire FFiletG Utritetimfifi in lnhi{h Eirlrts{ rlEPra!?lcr: *idri

b- Trlrs:di3r,5

A bEfl3 8or.or€d 4rdEs tlE od

Poltfoli o lr,lanagelr enD.ep undefdindiig,l€n r r..ul!.

]HT

Comrnr'rebr prid durinf, dE f Y

llorir!fts fin#id Srrvi!.. P.hntr [.idia.d

f rlnri.r &rBo -Qitn $.r" Shlr.llald.r & gs/

lisrilor,s {dvi'Giy' F-fi'l i|} rrhidt B;rllre "rE

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L The Financial details ofPortfolio Manager(Based on audited financial StatementsJFinancial highlights of Right Horizons Portfolio Management Pft Ltd. for the last 4 yearsare given as under:Particulars For the year

ended March3L,2016

For the yearended March30,2015



Profit treforedepreciation & tax &After Exceptional &Extraordinary Items INetof Taxl

1,768,242 557,760 [58s,469] (L,467,9s8)

Less: Depreciation 451,090 677,367 289,764 390,181Less: Provision for tax 148,300Less/[Add): Deferred [1s7,604) 1 q ' t 4q? [184,071] (7 4,918)

Less: Fringe Benefit TaxLess: Wealth TaxLess: Provision for Taxffor previous yearlProfit/[LossJ for the yearafter tax

726,456 [20s,100J (6e0.s62) (7,783,221)

Add/[LessJ: Balance B/Ffrom Previous vearBalance carried toBalance Sheet

9. Portfolio Performance on various schemesPortfolio Management performance ofthe Portfolio Manager for the last 4 years Based onModel Portfolio and in case of discretionary Portfolio Manager disclosure of performanceindicators calculated using weighted average method in terms of regulation 14 of the SEBI

IPortfolio ManagersJ Regulation 1993.

Portfoliol-er&rllslsg tz"l

1 Month 3 Months 6 Months 1 Year SinceInception

Nifty Plus Portfolio | +.ooVo l -t.toVo I r.g

CNX Nifty Index 4.59o/o -0.7 5o/o -0.89o/o 73.19o/o 70.29o/o

BSE 500 Index J.O J "/0 -t.84D/o 0.64o/o 76.44o/o 10.58%

t--iT|:r,***,,, y*,,:l::" *n'

17

CNX Midcap Index 6.680/o -4.360/o 4.BBot 19.990/o 1,4.75o/o

G-Sec Index 0.0070 0.000/o 0.009 0.00% 3.48o/o

6.85o/oNSE Quality 30 Index !.70o/o -3.200/o -4.27 5.29o/o 6.860/o

CNX Nifty Index 4.59o/o -0.7 5o/o -0.89o/o 13.I9o/o ll.32o/o

(

G-Sec Index 0.00%o 0.00% 0.0002 0.0070 2.940/oUnderserved , ,. .,.,r1':Portfol io . , . .

'2,r0*",'; t4.tl

CNX Niftv Index 4.59o/o -0.75% -0.99(b 13.l9o/o 4.0!o/o

CNX Niftv Index 4.590/o -0.7 5o/o -0.890/,0 t3.'1,9o/o 4.01o/o

Note: Performance for the period ending ] an 2017

10. Nature of Expenses

i) Investment Management & Advisory Fees:Management and Advisory fees charged may be a fixgd fee or a return based fee or acombination of both as detailed in the Schedule to the Portfolio Management Servicesagreement. The Fees may be charged upfront and/or at the end of a specified tenure asagreed between the Client and the Portfolio Manager.iiJ Custodian Fees:As may be decided between the Client and the Portfolio Manageriiil Registrar & Transfer Agent Fees:NILiv] Brokerage & Transaction Cost:The listed investments under Portfolio Management would be done through registeredmembers of the Stock Exchange(sJ who charge brokerage up to a maximum of 2.5o/o ofcontract value. In addition to the brokerage, trans4ction cost like network charges,turnover charges, stamp duty, transaction costs, turnovgr ta& Securities transaction tax orany other tax levied by statutory authorities, foreign trainsaction charges fif any) and othercharges on the purchase and sale of shares, stocks, bonds, deb! deposits, other financial

|i*,*:,*y*****"

instrumentsServices Pvt.basis. EntryClients.v] Service Tax:As applicable from time to time.vil Depository ChargesrAs applicable from time to time.viiJ Entry Load /Exit LoadAs may be mutually agreed to between the Client and the Portfolio ManagerviiiJ Certification and professional charges:Charges payable for out sourced professional services like accounting, auditing taxationand legal seruices etc. for documentation, notarizations, certifications, attestations requiredby bankers or regulatory authorities including legal fees etc.ixJ Incidental expensesiCharges in connection with day-to-day operations like courier expenses stamp duty,service ta& postal, telegraphic, and opening and operation of bank account, distributioncharges or any other out of pocket expenses as may be incurred by the Portfolio Manager.

11. TaxationThe following information is based on the law in force in India at the date hereof. Theinformation set forth below is based on the Portfolio Manager's understanding of the TaxLaws as ofthis date of Disclosure Document. The client should seek advice from his/her/itsown professional advisor if he/she/it is in any doubt regarding the taxation consequencesof investing in the Products offered under Portfolio Management Services.Income Tax:The maximum taxes rates applicable to different categories ofassess are as follows:

18

would also be levied by the broker [including Right Horizons FinancialLtd.J.The distribution services of RHFSPL if availed, will be on Arms-lengthor exit loads [if anyJ on units of Mutual Funds will also be charged from

Resident individual & HUFPartnership Firms &lndian CompaniesNon-resident IndiansForeign companies

30%o + surcharge I ifapplicableJ +Cess3070 + surchargeI If applicable] +cess30% + surcharge I If applicable)+ Cess40% + surchargeI if applicable]+Cess

Assesses Rate of surcharge applicable

Individuals (including NRIs/PIOsJ, HUFs,Non-Corporate FIIs if income exceeds Rs 1crore.

15o/o of surcharge on Income Tax andeducation cess of 3 percent is payable on thetotal amount oftax plus surcharge.

Domestic Companies where the taxableincome exceeds Rs. 1 crore but does notexceed Rs. 10 crore.

7o/o of surcharge on Income Tax andeducation cess of 3 percent is payable on thetotal amount of tax plus surcharge.

Domestic Companies where the taxableincome is in exceeds of Rs. Rs. L0 crore

L20/o of surcharge on Income Tax andeducation cess of 3 percent is payable on the

R I f,,,'*1,* :l*l:Y,::''' n'

19

total amount oftax plus surcharge.Foreign Companies where the taxableincome exceeds Rs. l crore but does not exceedRs. 10 crore.


Domestic Companies where the taxableincome is in exceeds of Rs. Rs. 10 crore


The Dividend received in respect of the shares and income received in respect of units ofMutual Fund held in the Products offered under the Portfolio Management Services isexempt from tax in the hands of investor.However, the dividend/income distribution on securities and units received by productsoffered under the Portfolio Management services will be after distribution tax on theamount of dividend/income distribution declared.

Capital Gains TaxaJ LOng r ermFor Individuals, HUF, Partnerships Firm and Indian CompaniesFrom October l, 20O4 in case of shares and securities and units of equity oriented schemessold on a recognized stock exchange, which are subject to Securities Transaction Tax[currently 0.t25o/o), the tax on Long Term Capital Gain would be Nil. Long term capitalgains in respect of other listed securities or units would be subject to tax at the lower of2070 [plus surcharge and education cessJ ofthe gains computed after cost indexationbl Short TermFor Individuals, HUF, Partnerships Firm and Indian Companies Short-term Capital Gainsare added to the total income. Total income including short-term capital gain is chargeableto tax as per the relevant slab rates. However, tax on short term capital gains on sale ofshares and units of equity oriented funds on a recognized stock exchange, which aresubject to Securities Transaction TaL would be @ lSo/rt (plus applicable surcharge and aneducation cessJ. Provisions regarding Dividend income and Bonus According to the

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Type of Distribution Rate ofTax (%) (Including Surcharge of 5.0% andEducation Cess of 3%o)

Dividends fromCompanies

16.9950/o

Income Distribution onUnits

Money MarketFunds

Other than MoneyMarket Funds

EquityOrientedFunds

Individuals and H.U.F. 28.84o/o 28.84o/o Nil

N t1 r

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provisions of Section 9aQ) of the Act, losses arising from the sale/redemption of unitspurchased within 3 months prior to the record date (for entitlement ofdividendsJ and soldwithin 9 months after such date, is disallowed to the extent of income on such units fotherthan on sale/redemptionJ claimed as tax exempt.According to the provisions of Section 9a[8] of the Act, if an investor purchases unitswithin 3 months before the record date (for entitlement of bonusJ and sells/redeems theunits within 9 months after that date, and by virtue of holding the original units, hebecomes entitled to bonus qnits, then the loss arising on transfer of original units shall beignored for the purpose of computing his income chargeable to tax. In fact, the loss soignored will be treated as coft ofacquisition ofsuch bonus units.Tax Deduction at SourceDividend income distributioh on securities and units is not taxable in the hands ofrecerver.TDS is deductible on interes{ income and would be deducted by the issuer ofsuch security.

12) Accounting Policies:

The following Accounting cy will be applied for the investments of Clients:

a] Investments in Equities, utual funds, Exchange Traded Funds and Debt instrumentswill be valued at closing prices ofthe exchanges (BSE or NSE as the case may beJ or

declared for the relevant scheme on the date of the reDortthe Repurchase Net Asset Vor any cutoff date or the market value of the debt instrument at the cutoff date.Alternatively, the last le prices on the exchange or the most recent NAV will bereckoned. In case of stru products, the portfolio will be valued at the face value oftheproduct until the expiry of e tenure.bJ Realized gains/ lossesPortfolio Manager and

be calculated by applying the first in/ first out principle. TheClient can adopt any specific norms or methodology for

valuation of investments or

on a case specific basis.ting the same as may be mutually agreed between them

cl For derivatives and fu and options, unrealized gains and losses will be calculated bymarking to market the open ns.d] Unrealized gains/losses the differences in between the current market values/NAVand the historical cost of the ecurities.eJ Dividend on equity and interest on debt instruments shall be accounted on

Fund dividend shall be accounted on receiDt basis. Otneraccrual basis. Further M

income like bank interest,

fJ Bonus shares shall be

rest on FD etc. shall also be accounted on receipt basis.only when the original shares on which the bonus

entitlement accrues are on the stock exchange on an ex-bonus basis.g) Right entitlement shall recognized only when the original shares on which the rightentitlement accrues are tra on the stock exchange on an ex-rights basis.

h) The cost of investment a uired or purchased shal l include brokerage, stamp duty and

HTORIZON|:r,:'r*r y.,::iff :" "'

any charge customarily incl ed in the brokers cost note/bought note.

The Accounting Policies and Standards as outlined above are subject to changes made fromtime to time by Portfolio Manager. However, such changes would be in conformity with theResulations.

13) Investors Services:

[iJ Details of investor relation officer who shall attendcomplaints are mentioned herein below:

the investor queries and

[ii] Grievance redressal and dispute settlement mechanism:Grievances, if any, that may arise pursuant to the portfolio Investment ManagementAgreement entered into shall as far as possible be redressed through the administrativemechanism by the Portfolio Manager and are subject to SEBI [Portfolio Managers)Regulations 1993 and any amendments made thereto from time to time. However, all thelegal actions and proceedings are subject to the jurisdiction of court in Mumbai only andare governed by Indian laws.The Portfolio Manager will endeavor to address all complaints regarding servicedeficiencies or causes for grievance, for whatever reason, in a reasonable manner and time.If the Investor remains dissatisfied with the remedies offered or the stand taken by thePortfolio Manager, the investor and the Portfolio Manager shall abide by the followingmechanisms:- All disputes, differences, claims and questions whatsoever arising befweenthe Client and the Portfolio Manager and/or their respective representatives shall besettled through Arbitration process as described in the Portfolio Investment ManagementAgreement or any Supplemental Agreement thereto.

CEO & Principal Officer

Date: fp b te . zrrY

Place: Bangalore

Compliance Officer

R6Ci-"rrRIZONlPnrtfol io i \4l nageit r

In . , , , , , , , . r . , * i , , r i , , e . r , . , r . L , , , L r

Name of the person: Anil RegoDesignation: Principal 0fficerAddress: #6, Ground Floor, Arekere Village, Opp. British Biologicals,

Bannerghatta Road, Barlgalore-5600 76.Email : a ni l rego@righthoTelephone: +91-080-65687503 to 5l,B

Rachna Rego,

t ]1