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Investor’s Code of Conduct

VentureX Fund I (Category I AIF)

1. Respect for Fund Processes

  • Honor all capital commitments and drawdowns on time.
  • Follow the procedures set out in the Fund Documents without unnecessary delay or disruption.

2. Transparency & Disclosure

  • Provide accurate KYC, AML, FATCA, and tax information at onboarding and whenever updated.
  • Promptly inform the Fund Manager of any changes in ownership, contact details, or regulatory status.

3. Confidentiality

  • Treat all Fund-related information (portfolio details, strategies, reports) as strictly confidential.
  • Do not share or publicize Fund information without prior written consent.

4. Professional Conduct

  • Engage with the Fund Manager, Trustee, and team members in a professional, respectful, and constructive manner.
  • Avoid conflicts of interest or actions that may harm the reputation of the Fund.

5. Compliance with Laws

  • Ensure that all investments in the Fund comply with applicable laws and regulations (SEBI, FEMA, RBI, Income Tax Act, etc.).
  • For non-resident investors, ensure compliance with FEMA and RBI approvals where required.

6. Non-Interference

  • Respect that investment decisions rest solely with the Fund Manager and Investment Committee.
  • Provide feedback or concerns through formal channels without interfering in day-to-day fund management.

7. Timely Communication

  • Respond promptly to Fund communications and requests for information.
  • Maintain open, transparent, and cooperative communication with the Compliance Officer and Fund team.

8. Tax Responsibility

  • Take responsibility for one’s own tax obligations arising from Fund distributions.
  • Provide tax-related documents (PAN, residency certificates, etc.) when requested.

9. Support Fund Integrity

  • Uphold the trust and integrity of the Fund through ethical conduct.
  • Report any suspected misconduct or irregularity to the Compliance Officer or Trustee.

10. Validity & Applicability

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.

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AIF Investor Code of Conduct | SEBI AIF Compliance & Rules