INVESTMENT ADVISORY DISCLOSURE

Pioneer Client Associates Private Limited (Client Associates) – Disclosures under SEBI (Investment Advisers) Regulations, 2013

Client Associates started its operations in 2002 and has long standing history of providing Wealth Management services to its clients. Over the years, Client Associates has included other verticals to its operations to include other than MF and Financial Products distribution and advisory, Real Estate Advisory, Lending Solutions, Investment Banking, Succession and Estate Planning to give all wealth related services to our clients under one roof.

Client Associates has set up independent Investment Advisory Services Vertical to comply with SEBI (Investment Advisers) Regulations, and in that regard please note the disclosure contents as given below.

Client Associates has set up an independent practice within the company structure to provide investment advisory services to its clients ('Client Associates IA Vertical' Or CAIA Vertical), which will be demarcated from and maintain an arm's length relationship with the other verticals of Client Associates which are engaged in research and distribution of mutual funds and other third party products without any financial liability.
Investment Advisory services shall be provided to you only after the CAIA Vertical assesses your risk profile and suitability of the product.
If you wish to avail the investment advisory services of the CAIA Vertical, you will be required to:
A) Complete and execute the Registered Investment Advisory Agreement.
B) Complete and regularly update the risk profiling and know-your client (KYC) form in the manner prescribed by Client Associates.
C) Complete and regularly update the Suitability profiling form in the manner prescribed by Client Associates.
The Investment Advisory fee payable by the client will be in accordance with the RIA Agreement. The SEBI guidance on charging of fee is clearly reflected in the RIA Agreement in the spirit of open and transparent communication with the clients as a longstanding policy of Client Associates. Any fees and charges, payable by you for the execution/distribution services availed by you from Client Associates, must be paid directly to the respective vertical and not through the CAIA Vertical.
Client Associates shall rank the products it offers to clients based on multiple factors as per its internal research. Client Associates shares all the relevant information of various investment products monthly and periodically through structured reports, specific recommendations and otherwise. We encourage you to go through the same and would like to specifically draw your attention to the key features, track record, warnings, risk profile, risk factors etc. In case you need any clarification, please get in touch with your Relationship Manager at CAIA Vertical
CAIA Vertical shall maintain complete confidentiality of all information provided by you and shall not disclose any such information, without your prior consent except if such disclosure is required to be made in compliance with any applicable law or regulatory direction.
CAIA Vertical while advising on offshore investments does not act as agent for any overseas mutual funds or any other foreign financial services company. The advice provided by CAIA on such offshore investments shall not amount to solicitation.

INFORMATION ABOUT CLIENT ASSOCIATES:

A)	Licensing: Pioneer Client Associates Private Limited (Client Associates), a company registered, governed and incorporated under the Companies Act, 2013, offers investment research, investment advisory services, permitted referral services, distribution of mutual funds and other permitted third party financial products with no financial liability. It is registered with and regulated by the Securities and Exchange Board of India (SEBI) as a Registered Investment Advisor and also distributor of Mutual Funds and other financial products.
B)	Details of SEBI registrations: Registered as investment advisor with SEBI registration number INA100010660.
C)	Disciplinary history: No material action has been taken against Client Associates by any regulator.

CONFLICT OF INTEREST

At Client Associates, the advisory and execution roles are clearly segregated and both of these teams work in close coordination yet independently to avoid conflict of interest situations. The permitted execution/distribution of third party products, including execution/distribution of mutual funds, etc., are carried out from a separate vertical which acts independently and they have no common organisation hierarchies. We have maintained segregated organisation structures and controls to ensure independence under SEBI Investment Advisers Regulations, 2013 including segregation and controls between CAIA Vertical and the team executing on distribution of products. The Distribution team of Client Associates may receive, from time to time, commission from third party product providers for distributing their products.

Investment Advisory Details

Investment Adviser: Pioneer Client Associates Private Limited
Type of Registration- Non-Individual
Registration number- INA100010660
Validity of registration- Perpetual
Address- 2nd Floor, Block B, Vatika Towers, Golf Course Road, Sector 54, Gurgaon-122002

Principal Officer – Pawan Kumar,
Contact Details
Email id: pawankumar@clientassociates.com
Contact no: +91 (0) 124 4995400
Corresponding SEBI office address- SEBI Northern Regional Office (NRO), 8th Floor, Plate B, East Kidwai Nagar, NEW DELHI- 110023