Avendus Wealth Management Private Limited

Allegations: THE FUND IS AN INVESTMENT VEHICLE AND AS PER INDIAN EXCHANGE CONTROL REGULATIONS, IS CATEGORISED AS FOREIGN OWNED AND CONTROLLED ON ACCOUNT OF ITS SPONSOR AND INVESTMENT MANAGER NOT BEING OWNED AND CONTROLLED BY RESIDENT INDIANS. THE FUND IS REQUIRED TO FOLLOW FOREIGN DIRECT INVESTMENT (FDI) NORMS. THE FUND HAD ERRONEOUSLY INVESTED IN ONE SECURITY WHICH IS PROHIBITED UNDER FDI AND HAS SINCE EXITED WITHIN SHORT SPAN OF 6 DAYS. DEPARTMENT FOR PROMOTION TO INDUSTRY AND INTERNAL TRADE (DPIIT) HAS DIRECTED TO APPLY TO RBI FOR COMPOUNDING OF SAID MATTER. SUBSEQUENTLY, RBI HAS ACCEPTED THE COMPOUNDING APPLICATION OF THE FUND AND VIDE COMPOUNDING ORDER DATED JANUARY 17,2022 HAS LEVIED A PENALTY OF INR 11,90,156/- ON THE FUND. THE SAID PENALTY HAS BEEN PAID TO RBI AND THE MATTER STAND DISPOSED" Status: Final Sanction Detail: RBI HAS ACCEPTED THE COMPOUNDING APPLICATION OF THE FUND AND VIDE COMPOUNDING ORDER DATED JANUARY 17,2022 HAS LEVIED A PENALTY OF INR 11,90,156/- ON THE FUND. THE SAID PENALTY HAS BEEN PAID TO RBI AND THE MATTER STANDS DISPOSED Summary: AS EXPLAINED IN PT. 7 AND PT 10, MATTER STANDS DISPOSED

Allegations: THE FUND IS AN INVESTMENT VEHICLE AND AS PER INDIAN EXCHANGE CONTROL REGULATIONS, IS CATEGORISED AS FOREIGN OWNED AND CONTROLLED ON ACCOUNT OF ITS SPONSOR AND INVESTMENT MANAGER NOT BEING OWNED AND CONTROLLED BY RESIDENT INDIANS. THE FUND IS REQUIRED TO FOLLOW FOREIGN DIRECT INVESTMENT (FDI) NORMS. THE FUND HAD ERRONEOUSLY INVESTED IN ONE SECURITY WHICH REQUIRED PRIOR GOVERNMENT APPROVAL. AFTER THE SAME WAS REALISED, THE FUND EXITED THE INVESTMENT. THE FUND HAS APPROCHED RESERVE BANK OF INDIA FOR COMPOUNDING OF THE MATTER. THE RESERVE BANK OF INDIA HAS INSTRUCTED TO SEEK POST FACTO GOVERNMENT APPROVAL FROM EPARTMENT OF PROMOTION TO INDUSTRY AND INTERNAL TRADE (DPIIT) FOR THE INVESTMENT AND THERAFTER APPLY FOR COMPOUNDING TO RESERVE BANK OF INDIA. Status: Final Sanction Detail: WE HAVE RECEIVED A LETTER DATED DECEMBER 11, 2023 FROM DEPARTMENT OF FINANCIAL STATING THAT THE SAID TRANSACTION DOES NOT REQUIRE GOVERNMENT APPROVAL. WE HAVE REPORTED THE TRANSACTION ON FIRMS PORTAL OF RBI AND CONSEQUENTLY PAID A LATE SUBMISSION FEES OF INR 22,500 TO RBI. ACKNOWLEDGEMENT DATED 31ST MAY 2024 (ATTACHED ANNEXURE C) HAS BEEN RECEIVED FROM RBI ABOUT RECEIPT OF THE LATE SUBMISSION FEES AGAINST THE REPORTED TRANSACTION. NO FURTHER ACTION REQUIRED FROM OUR END AND THE MATTER STAND RESOLVED. Summary: WE HAVE RECEIVED A LETTER DATED DECEMBER 11, 2023 FROM DEPARTMENT OF FINANCIAL STATING THAT THE SAID TRANSACTION DOES NOT REQUIRE GOVERNMENT APPROVAL. WE HAVE REPORTED THE TRANSACTION ON FIRMS PORTAL OF RBI AND CONSEQUENTLY PAID A LATE SUBMISSION FEES OF INR 22,500 TO RBI. ACKNOWLEDGEMENT DATED 31ST MAY 2024 (ATTACHED ANNEXURE C) HAS BEEN RECEIVED FROM RBI ABOUT RECEIPT OF THE LATE SUBMISSION FEES AGAINST THE REPORTED TRANSACTION. NO FURTHER ACTION REQUIRED FROM OUR END AND THE MATTER STAND RESOLVED.