Disclosure – Pavan Kumar Manchiraju

The particulars in this Disclosure Document are provided under the SEBI (Investment Advisers) Regulations, 2013. Its purpose is to help prospective clients make an informed decision regarding engagement of the Investment Adviser.

For this document, the Investment Adviser is Pavan Kumar Manchiraju, registered with the Securities and Exchange Board of India as an Investment Adviser under Registration No. INA000018975 dated 22 March 2024, having its registered office at Flat 1001, Tower – 5, Urbana BNRI Complex, Anandapur, Kolkata – 700107, India.

A. Description about Pavan Kumar Manchiraju

History, Present Business and Background: As an adviser, Pavan Kumar Manchiraju aligns his interests with those of the client and provides advice based on the client’s risk profile. He seeks to understand each client’s return expectations, risk appetite, and financial goals to determine an appropriate asset allocation.

Terms & Conditions for Advisory Services: Services may include buying and selling of securities for an agreed fee structure and time period. Detailed terms and conditions are defined in the agreement executed between the client and Pavan Kumar Manchiraju.

B. Disciplinary History

No action has been taken against Pavan Kumar Manchiraju as an Investment Adviser by any regulator.

C. Investment Advisory Audits

Disclosures regarding compliance with annual audit requirements under Regulation 19(3) of SEBI IA Regulations for the last and current financial year have been made. No other affiliations or intermediary registrations exist.

D. Consideration Disclosure

Pavan Kumar Manchiraju does not receive or expect to receive any consideration, remuneration, or compensation for distribution or execution services from issuers of securities advised.

E. Stock Broker / Intermediary Referral Disclosure

• Does not recommend any stock broker or intermediary to clients.
• No commission or fee-sharing arrangement exists with any intermediary.

F. Personal Holdings Disclosure

Not registered as a broker with SEBI and not engaged in proprietary trading. May invest in securities for personal account in the future.

G. Conflict of Interest Disclosure

No conflict of interest exists. Not engaged in stock broking, depository, research, portfolio management or mutual fund distribution activities.

H. Product / Security Disclosure

Clients should read key features, performance track record, and official disclaimers of investment products available on sebi.gov.in, nseindia.com and bseindia.com before investing.

I. Disclaimers in Product Documents

Clients will be informed of all disclaimers, warnings, and product-specific risks in materials used by the adviser prior to investment.

J. Standard Risk Factors

• All investments are subject to market risk; no assurance of returns.
• Past performance is not indicative of future results.
• Government policy changes and economic factors may affect portfolios.
• Global events and force majeure conditions can impact investments.
• Product names and categories do not imply safety or guaranteed returns.
• Debt instruments carry interest rate, reinvestment and default risks.
• Unlisted securities may have liquidity constraints.
• Derivatives involve leverage, correlation and pricing risks.
• NAV fluctuations and settlement delays can affect returns.
• Low-rated instruments increase overall portfolio risk.

K. General Risk

Clients should carefully review all documents and understand risks before acting on advice. The adviser shall maintain confidentiality of client data except where disclosure is required by law.

L. Investor Services

Clients may email complaints to pavanm.mail@gmail.com.