Grievance Redressal Policy

The route at a glance

A query or complaint may arise from a lack of explanation or clarification, or from a deficiency of service. A deficiency of service may include shortfalls in the expected delivery standards, whether on account of the adequacy of the facilities available or the conduct of our staff. We treat every such communication seriously, and this page sets out how to reach us, what we commit to, and how a matter may be escalated if our response does not satisfy you.

1. 1

   Client Servicing Team

   Where

   Complaints form, hemanth@flamebackcapital.com, +91 97052 35263

   Commitment

   Acknowledgement within 2 business days; substantive response within 7 business days.

   Next step

   Escalate to Level 2 if unanswered in 7 business days or if the response does not satisfy you.

2. 2

   Compliance Officer

   Where

   kranthi@flamebackcapital.com, +91 98850 12380

   Commitment

   Reply within 7 business days of your escalation; redressal within 30 days of receipt, subject to the information needed to redress it.

   Next step

   Escalate to SEBI SCORES if unanswered or if the response does not satisfy you.

3. 3

   SEBI SCORES

   Where

   scores.sebi.gov.in (opens in a new tab)

   Commitment

   Our action taken report within 21 calendar days of receipt on SCORES.

   Next step

   Seek a first review within 15 calendar days of the action taken report.

4. 3A

   First review: APMI

   Where

   Through SCORES.

   Commitment

   A revised action taken report within 10 calendar days.

   Next step

   Seek a second review within 15 calendar days of that report.

5. 3B

   Second review: SEBI

   Where

   Through SCORES.

   Commitment

   As determined by SEBI.

   Next step

   Online dispute resolution remains available if the matter is not resolved.

6. 4

   Online Dispute Resolution

   Where

   smartodr.in (opens in a new tab)

   Commitment

   Online conciliation, followed by online arbitration if conciliation is unsuccessful.

   Next step

   Available where the grievance was not satisfactorily resolved, or at any stage of the escalations above.

Level 1: Client Servicing Team

A query or complaint may be made in writing, by e-mail, orally or by telephone.

Every complaint receives a reference number when we acknowledge it.

Level 2: Compliance Officer

If you do not receive a response within 7 business days of writing to the Client Servicing Team, or you are not satisfied with the response received, you may escalate the matter to our Compliance Officer.

You may expect a reply from the Compliance Officer within 7 business days of your escalation.

In every case, we will redress your grievance within 30 days of receipt, subject to your having provided all the information required to redress it. Where a complaint reaches us through SEBI SCORES, we will resolve it and upload our action taken report within 21 calendar days of receipt on that platform.

Accessibility assistance and grievances

We aim to make our website, mobile application and investor documents usable by persons with disabilities, and we are working to align our digital platforms with the Web Content Accessibility Guidelines 2.1, the Indian Standard IS 17802 and the Guidelines for Indian Government Websites. If any part of our website, application or documentation is difficult for you to access or use, please tell us. We treat this as a grievance and not as feedback, and it is handled through the dedicated channel below.

Who to contact

Where no separate nodal officer has been designated, our Compliance Officer discharges this role, and the contact details at Level 2 above apply.

What helps us resolve it quickly

• The page or screen where the difficulty arose, and its web address if you have it.
• What you were trying to do.
• The assistive technology, browser, device or operating system you were using, if you know it.
• How you would prefer us to reply: e-mail, telephone, or an accessible document format.

What we commit to

• We acknowledge every accessibility grievance within 2 business days, with a reference number.
• We provide a substantive response within 7 business days, and in any event redress the grievance within 30 days.
• While the issue is being fixed, we offer an alternative means of completing the same task, including assisted on-boarding and know-your-client processes, a human-assisted video or voice-assisted alternative, and documents supplied in an accessible format on request. No investor will be turned away because a digital platform is not usable.
• Where a fix requires a change to the platform itself, we tell you what is being done and by when, and we record the item for remediation.

If you are not satisfied

An investor facing accessibility-related issues on the digital platforms of a SEBI-regulated entity may lodge an accessibility-related complaint against that entity on SCORES. The escalation route is therefore the same as for any other complaint: SCORES, then a first review by the Association of Portfolio Managers in India as the Designated Body, then a second review by SEBI, with online dispute resolution available as set out below.

Level 3: SEBI SCORES

If you are not satisfied with our response, or if you do not receive a response, you may lodge your complaint with SEBI on the SCORES platform.

Lodge a complaint on SCORES

Reviews and timelines

You may also write to any office of SEBI, or to the Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (East), Mumbai - 400 051.

Level 4: Online Dispute Resolution

SEBI has established a common Online Dispute Resolution Portal which harnesses online conciliation and online arbitration for the resolution of disputes arising in the Indian securities market. If your grievance is not resolved satisfactorily, you may initiate dispute resolution through that portal.