Post-Investment Portfolio Monitoring Policy

1. Objective

This Policy establishes the framework for monitoring the performance, governance, and compliance of investee companies post-investment, in order to:

• Protect the interests of Contributors
• Ensure adherence to SEBI (AIF) Regulations, 2012
• Mitigate risks and maximize portfolio value creation

2. Scope

This Policy applies to all investments made by the Fund and covers:

• Listed and unlisted investee companies
• Pre-IPO, IPO, and post-listing positions
• Co-investments made alongside the Fund

3. Monitoring Responsibilities

The Investment Manager shall:

• Establish systems for continuous monitoring of portfolio companies
• Designate Key Executives, Investment Committee members, and sector-specific research analysts for monitoring
• Report periodically to the Trustee and Contributors

4. Monitoring Parameters

The Investment Manager shall monitor, assess, and record the following parameters for each portfolio company:

• Financial Performance: revenue growth, profitability, cash flows, debt profile, and capital adequacy.
• Operational Metrics: scalability, customer traction, and efficiency vs sector benchmarks.
• Governance & Compliance: adherence to governance standards, SEBI regulations, covenants, and statutory filings.
• Capital Structure: promoter holdings, dilution, institutional/strategic investors, and leverage levels.
• Management & Strategy: capability, succession planning, alignment with Fund objectives.
• Risk & ESG: financial, operational, reputational, and ESG compliance.
• Internal Assessment: review notes, risk ratings, exit-readiness evaluations.

5. Information & Access Rights

• Quarterly/annual financial and operational reports
• Access to management and Board/observer meetings
• Site visits and audits where necessary

6. Reporting & Disclosures

• Quarterly Monitoring Reports for internal review and Trustee oversight
• Investor Reports circulated quarterly in line with Regulation 28 of SEBI AIF Regulations
• Material adverse events (fraud, default, penalty, key resignations) reported to Trustee and SEBI within 7 business days

7. Corrective Actions

• Engage with management for corrective measures
• Exercise shareholder/Board rights to safeguard Contributor interests
• Initiate divestment if risk-return profile is adversely impacted

8. Record Keeping & Compliance

• Documentation of monitoring activities retained for minimum 8 years
• Trustee oversight with right to independent audits
• Policy forms part of Fund Documents and is binding on Contributors, Investment Manager, and Trustee

9. Validity & Applicability

This Policy is effective from 01st March 2025, the date of SEBI registration grant to VentureX Fund I, and shall remain valid until the full distribution of the Fund’s assets and closure in accordance with SEBI (AIF) Regulations, 2012.