Contingency Policy – VentureX Fund

(In accordance with SEBI (Alternative Investment Funds) Regulations, 2012)

1. Objective

This Contingency Policy is established to ensure continuity, stability, and protection of investor interests in the event of death, incapacity, disability, or kidnapping of any Key Executive of the Investment Manager of VentureX Fund (“the Fund”).

2. Key Executives Covered

This Policy applies to the following Key Executives of the Investment Manager:

Mr. Rajesh Kumar Singla
Ms. Urmila Rani Singla
Mr. Maneesh Nath
Ms. Ishima Singla

3. Contingency Triggers

This Policy shall come into effect upon occurrence of any of the following events:

Death of a Key Executive
Permanent or temporary incapacity or disability rendering the Key Executive unable to perform duties
Kidnap or unlawful detention
Mental or physical illness leading to incapacity

4. Immediate Measures

The Board of Directors/Designated Partners of the Investment Manager shall convene a meeting within 7 business days of the occurrence of a Contingency Trigger.
The Trustee of the Fund shall be notified in writing within 48 hours.
SEBI shall be informed of such change in Key Executive(s) within 15 days, in accordance with Regulation 20(1) of the SEBI AIF Regulations.

5. Interim Management

In case of temporary incapacity or kidnap, the duties of the affected Key Executive shall be delegated to remaining Key Executives, subject to Board approval. If required, an Interim Committee comprising not less than two unaffected Key Executives shall oversee fund operations until the contingency is resolved.

6. Succession & Replacement Process

In case of permanent death or incapacity, the Board of the Investment Manager shall, within 30 business days, appoint a replacement Key Executive with requisite experience and SEBI eligibility criteria. Appointment shall be subject to Trustee approval and SEBI intimation, in line with Regulation 20 of AIF Regulations. Investors holding at least 75% (by value of commitments) (“Super-Majority”) shall have the right to approve or reject such appointment.

7. Continuity of Fund Operations

All investment, divestment, and operational decisions shall remain binding and valid if approved by remaining Key Executives and Trustee. In absence of quorum of Key Executives, the Trustee may appoint an Independent Investment Committee or an Alternate Investment Manager, subject to SEBI approval, to safeguard investor interests.

8. Investor Protection Provisions

Investors shall be promptly informed of the contingency and proposed remedial measures within 15 business days. In case of failure to appoint a successor or alternate within 90 business days, investors holding a Super-Majority shall have the right to:

Remove the existing Investment Manager and appoint a new SEBI-registered manager; or
Wind-up the Fund in accordance with Regulation 29 of SEBI AIF Regulations.

9. Record & Compliance

All proceedings, approvals, and appointments under this Policy shall be duly recorded in minutes and notified to SEBI.

10. Validity & Applicability

This Policy shall be effective from 23rd July 2024, being the date of grant of SEBI registration to VentureX Fund I, and shall remain valid until the full distribution of the Fund’s assets and formal closure of the Fund in accordance with SEBI (AIF) Regulations, 2012.