Legal and Compliance

1. SEBI Registration Information: 

JWA Wealth Private Limited (hereinafter referred to as “JWA” or “Investment Advisor”) is a non-individual Securities and Exchange Board of India (SEBI) registered Investment Adviser having SEBI Registration No. INA000021146 (Valid until suspended or cancelled by SEBI) and BASL Membership ID: 2356.

Registration details: 

Registered Office: 5th Floor B Wing Supreme Business Park, Hiranandani BHD Lake Castle Bldg. Powai, Mumbai – 400076, Maharashtra

Telephone: +91 7770025145

Principal Officer: Name: Apoorv Joshi, contact number: 9028601484, Email: [email protected]

Compliance Officer: Name: Radha Gupta, contact number: 7770025145, Email: [email protected]

Corresponding SEBI regional/local office address: Securities and Exchange Board of India (SEBI) SEBI Bhavan, Plot No. C4-A, “G’ Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400 051.

JWA, through a separately identifiable division, is also a mutual fund distributor and portfolio management service provider. It’s AMFI Registration no. is 316290 & APMI Registration no. is APRN07504.

2. Grievance Redressal 

Step 1: Escalation Matrix:

Please find below escalation matrix to facilitate an easy approach for clients before they file any grievance with SEBI.

Customers may directly submit their complaints at [email protected] where our dedicated team will address them promptly and efficiently.

Step 2: If not satisfied with the response provided by JWA you can lodge your grievances with SEBI at https://scores.sebi.gov.in/scores- in or you may also write to any of the offices of SEBI. For any queries, feedback or assistance, please contact SEBI Office on Toll Free Helpline at 1800 22 7575 / 1800 266 7575.

Step 3: Alternatively, if you are not satisfied, you can also access a common Online Dispute Resolution Portal (“ODR Portal”) at https://smartodr.in/login under Investor Login to lodge a complaint.

3. Investor Complaints – Monthly Summary Table

NIL as the Company was licensed in Oct’25

4. Investor Charter

In accordance with SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/80 dated June 02, 2025, the Investor Charter for Investment Advisers is available on: :: SEBI Investor | Investor Charter ::

5. Compliance Audit Report Status

In accordance with Regulation 19(3) of SEBI (Investment Advisers) Regulations, 2013, the Company conducts annual compliance audit and publishes the status on its website as follows:

Adverse Findings of Audit (If Any) and Action Taken: NA as the company was licensed in Oct’25.

6. Client Level Segregation Certificate

JWA is a SEBI registered Investment Adviser providing Investment Advisory Services to its clients. JWA also provides distribution services through separately identifiable departments/divisions as per the client level segregation requirements under Regulation 22 of the SEBI (Investment Advisers) Regulations, 2013.

Important Note on Client Level Segregation:

• Existing clients who wish to take advisory services will not be eligible for availing distribution services within the group/family of the Investment Adviser.
• Similarly, existing clients who wish to take distribution services will not be eligible for availing advisory services within the group/family of the Investment Adviser.
• A new client will be eligible to avail either advisory or distribution services within the group/family of Investment Adviser. The option to avail either advisory services or distribution services shall be made available to such client at the time of on-boarding.
• The Investment Adviser, wherever available, advises direct plans (non-commission based) of products only.

Annual certificate confirming compliance with client level segregation requirements as specified in Regulation 22 of the SEBI (Investment Advisers) Regulations, 2013:

NA – The company was licensed in Oct’25.

7. Disciplinary History

“No action has been taken against the Company as an Investment Adviser by any regulator.”

8. Affiliations with Other Intermediaries

JWA Wealth Pvt Ltd. is a group company of Jupiter Wealth Advisors Limited, an independent wealth manager headquartered in DIFC, Dubai. Jupiter Wealth offers its clients a comprehensive range of services and bespoke solutions in the areas of investment and wealth management, family office services, corporate finance advisory, risk management and consolidated reporting.

Address: Jupiter Wealth Advisors Limited, Office 104-105, Liberty House, DIFC, PO BOX 482045, Dubai, UAE

The Investment Adviser maintains an arm’s length relationship between its activities as an investment adviser and other activities of its group/affiliates/associates.

9. Disclosure of Holding or Position in Financial Products

The Investment Adviser and/or its associates do not have any financial interest, beneficial ownership, or other material conflict of interest in the securities or financial products mentioned in this advice. The Adviser and its associates also do not have any actual or potential conflicts arising from personal holdings in these securities.

10. Disclaimers and Disclosures

This website is provided by JWA Wealth Private Limited (the “Investment Adviser”) solely for general informational purposes and is not intended to be, nor shall it be construed as, an invitation, inducement, recommendation or solicitation to invest in or purchase any product or service. The Investment Adviser is registered with SEBI under the applicable regulations governing investment advisory services in India. However, registration does not imply any guarantee of performance of the returns of any investment.

General Investment Risk
The Investment Adviser provides investment advisory services which are inherently subject to market‐risks, including fluctuations in value of securities, funds, financial products and other instruments. The Investment Adviser makes no guarantee, warranty or representation (express or implied) as to the accuracy of any information, the timing of any investment, the performance of any investment or that any client will experience any profits or avoid losses. Historical performance of any investments or portfolios shall not be taken as an indication or guarantee of future results. Any assured, fixed or guaranteed‐return schemes (or any schemes purporting similar nature) are prohibited for clients of the Investment Adviser and no such scheme will be offered by the Investment Adviser.

Fee Basis; No Custody of Client Funds or Securities

The Investment Adviser shall accept only fees for investment advisory services from clients. The Investment Adviser shall not accept any funds or securities into its account from the client on the client’s behalf and does not act as custodian of client funds or securities. Clients should ensure that all funds or securities transactions (purchase, sale, transfer) are effected through their own accounts with appropriate intermediaries.

Client Consent & Trade Execution

The Investment Adviser will not execute, carry-out or effect any purchase or sale order on behalf of the client unless the client gives specific and explicit prior consent for each trade. Clients are advised not to grant any power of attorney or unlimited authorisation to the Investment Adviser to execute trades on their behalf without express written consent for each transaction.

Risk Profiling, Suitability & Ongoing Monitoring

Before providing services, the Investment Adviser shall carry out a detailed risk-profiling and suitability assessment of the client and communicate the assessed risk profile to the client. The client must provide their consent on the completed risk profile. The services provided by the Investment Adviser will align with the assessed risk profile and investment objectives of the client. Ongoing monitoring and review of the risk-profile and suitability will be carried out at periodic intervals or when material changes occur.

Liability Disclaimer

Neither the Investment Adviser nor any of its employees, directors, agents or affiliates shall incur any liability for any loss which a client may suffer by reason of (i) any diminution in the value of the assets under advice; (ii) non-performance or underperformance of securities, funds or other investments recommended; (iii) any market, economic, political or other conditions beyond the control of the Investment Adviser. The client acknowledges that investments are subject to risks and may result in loss of capital.

Security Notice

The Investment Adviser will never ask for the client’s login credentials (such as user ID/password), OTPs, PINs or any sensitive access codes for the client’s Trading Account, Demat Account or Bank Account. Clients should never share such information with anyone, including the Investment Adviser or its representatives.

KYC / Account Maintenance Advice

KYC is a one time exercise while dealing in securities markets – once KYC is done through a SEBI registered intermediary (Broker, DP, Mutual Fund etc.), you need not undergo the same process again when you approach another intermediary. Clients are required to provide complete and accurate KYC information including identity proof, address proof, and PAN card details.

Non-Exchange Products

Some investment products or services (for example mutual funds, insurance, corporate fixed deposits, tax-free bonds, portfolio management services, advisory/distribution of non-exchange traded products) may not be traded on a recognised stock exchange and hence may not fall under the purview of exchange investor-grievance or arbitration forums. Clients are advised to note this distinction and understand that access to dispute-resolution forums may differ accordingly.

Regulatory Status; Verification; Beware of Assurances

Clients are advised to deal only with bona-fide investment advisers registered with SEBI. Clients may verify the registration status of any investment adviser via the SEBI website. Beware of entities or schemes promising assured or guaranteed returns, or schemes labelled as “fixed returns” when marketed by an investment adviser. Such schemes may be contrary to law or regulatory guidance.

General Information Only; No Personalised Advice Unless Engaged

The information provided on this website is only for general informational purposes and does not constitute personalised investment advice. Clients should not rely solely on information contained herein. Before making any investment decision, clients must consider their own investment objectives, financial circumstances, risk-tolerance, and consult independent professional advisors (such as tax, accounting, legal or financial) where appropriate. The Investment Adviser does not make any representation as to the suitability of any product or service for the client’s specific circumstances unless and until a formal engagement is entered into and risk-profiling and suitability assessment have been completed.

Changes to Information / Material Updates

The contents of this website have been prepared on a “best-effort” basis and are “as-is”, “as-available”. The Investment Adviser makes no warranty or representation (express or implied) regarding the accuracy, adequacy or completeness of any information or materials contained herein. The Investment Adviser may at any time edit, alter or remove any information, product or service described herein in whole or in part without prior notice. The Investment Adviser shall not be liable for any action taken, omission or reliance made by any person based on the content of this website.

Investor Acknowledgement

By continuing to engage with the Investment Adviser or by using this website, the client acknowledges having read and understood this disclosure and disclaimer and agrees that the advisory services will be offered and accessed only in accordance with the terms and conditions in effect between the client and the Investment Adviser.

The information provided on website is not intended to be used by investors as the sole basis for investment decisions, who must make their own investment decisions, based on their own investment objectives, financial positions, suitability to risk return profile and their needs before investing. The contents herein above shall not be considered as an invitation or persuasion to trade or invest. Investors should do thorough research and make independent judgment with regard suitability, profitability, and fitness of any product or service offered herein above or consult your financial manager/advisor before making an investment.

Distribution Disclaimer

JWA Wealth Private Limited (“JWA”) acts as a distributor for various third-party products and services such as Mutual Funds, Insurance, Corporate Fixed Deposits, Tax-Free Bonds, Sovereign Gold Bonds, Global Investing, and others. These products are not exchange-traded and therefore disputes relating to them do not fall under the purview of stock exchange investor grievance or arbitration mechanisms. All transactions in these products are executed directly with the respective product issuers or intermediaries.

Brokerage and commissions, where applicable, shall not exceed limits prescribed by SEBI or other regulatory authorities. JWA reserves the right to determine eligibility criteria for clients availing its distribution services and to modify or withdraw any service at its sole discretion, subject to regulatory guidelines.

The information provided on this website, research reports, or any communication shared by JWA is intended for informational purposes only and should not be construed as investment advice, solicitation, or an offer to buy or sell any securities. Investors are advised to make their own investment decisions after considering their financial situation, objectives, risk tolerance, and to seek independent professional or tax advice wherever necessary.

Investing in mutual funds and other market-linked products involves risk, including the possible loss of principal. Net Asset Values (NAVs) of schemes may rise or fall depending on market movements. Certain factors such as liquidity constraints, redemption suspensions, segregation of portfolios, or winding-up of schemes may also impact investment value and timelines.

Foreign currency denominated or overseas investments are subject to additional risks including exchange rate fluctuations and geopolitical developments. Derivative or leveraged products involve significant risk and may not be suitable for all investors.

The contents of this website are subject to change without prior notice. While all efforts are made to ensure accuracy, JWA makes no warranty, express or implied, regarding the completeness, reliability, or suitability of any information provided. JWA and its affiliates accept no liability for any direct, indirect or consequential loss arising from reliance on such information or services.

This website and its content are intended for residents of India and for distribution in jurisdictions where it is lawful to offer such products and services. Persons accessing this website from outside India must ensure compliance with local laws and regulations before using any information or services offered herein.

By accessing this website, you acknowledge that you have read, understood, and agreed to this Distribution Disclaimer and to the terms and conditions governing use of JWA’s services and information.

11. Prohibition on Association with Unregistered Entities

In accordance with SEBI (Intermediaries) (Amendment) Regulations, 2024, the Investment Adviser does not have any direct or indirect association with any person who provides advice or recommendation in respect of securities without being registered with or otherwise permitted by SEBI, or who makes any claim of returns or performance in respect of securities without being permitted by SEBI.

12. Code of Conduct Compliance

The Investment Adviser and all its partners, principal officer and persons associated with investment advice comply with the Code of Conduct as specified in the Third Schedule of the SEBI (Investment Advisers) Regulations, 2013.

13. Most important Terms and Conditions (MITC)

As per SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/19 dated February 17, 2025, the following Most Important Terms and Conditions are disclosed:

a) The Investment Adviser shall only accept payments towards its fees for Investment Advisory Services and is not permitted to accept funds or securities in its account on the client’s behalf.

b) The Investment Adviser does not guarantee returns, accuracy, or risk-free investments. All advice is subject to market risks, and there is no assurance of any returns or profits.

c) Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the Investment Adviser.

d) Investment advice, only related to securities shall fall under the purview of SEBI. In case of any services offered by Investment Adviser related to products/services not under the purview of SEBI, Investment Adviser shall make disclosure to the client and take appropriate declaration and undertaking from the client that such products/services and the services of Investment Adviser in respect of such products/services do not come under regulatory purview of SEBI and that no recourse is available to the client with SEBI for grievances related to such products/services or services of Investment Adviser in respect of such products/services.

e) This agreement is for the investment advisory services provided by the Investment Adviser and Investment Adviser cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client without his/her/its specific and positive consent on every trade. Thus, the client is advised not to permit Investment Adviser to execute any trade on his/her/its behalf without explicit consent.

f) The fee charged by Investment Adviser to the client will be subject to the maximum of amount prescribed by SEBI/Investment Adviser Administration and Supervisory Body (IAASB) from time to time (applicable only for Individual and HUF Clients).

Note:

(i) The current fee limit under Fixed Fee mode is Rs 1,51,000/- per annum per family of client. Under Assets under Advice (AUA) mode, maximum fee limit is 2.5 per cent of AUA per annum per family of client.

(ii) The Investment Adviser may change the fee mode at any time with the client’s consent; however, the maximum fee limit in such cases shall be higher of fee limit under the fixed fee mode or 2.5 per cent of AUA per annum per family of client.

(iii) The fee limits do not include statutory charges.

(iv) The fee limits apply only for investment advice related to securities under purview of SEBI.

(v) The fee limits do not apply to a non-individual client / accredited investor.

g) The Investment Adviser may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is maximum one year. In case of premature termination of the Investment Adviser services by the client or the Investment Adviser, the client shall be entitled to seek refund of proportionate fees only for unexpired period. However, Investment Adviser is entitled to retain a maximum breakage fee of not greater than one-quarter fee.

h) Fees to Investment Adviser may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM), managed by BSE Limited (i.e. currently recognized IAASB).

i) The Investment Adviser is expected to know the client’s financial details for providing services. Hence, the client is required to share the financial information (e.g. income, existing investments, liabilities, etc.) with the Investment Adviser.

j) The Investment Adviser is required to carry out the client’s risk profiling and suitability analysis before providing services and thereafter on an ongoing basis. The services provided will be in line with the assessed risk profile. Investment Adviser shall also communicate the assessed risk profile to the client.

k) As part of conflict of interest management, the client or the client’s family members will not be provided any distribution services by Investment Adviser or any of its group entity/ family members. Investment Adviser shall, wherever available, advice direct plans (non-commission based) of products only. The Investment Adviser shall endeavour to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.

l) For any grievances,

Step 1: The client should first contact the Investment Adviser using the details on its website or following contact details:

Kindly refer to Grievance Redressal in Point No. 2

Step 2: If the resolution provided by Investment Adviser is unsatisfactory, the client can lodge grievances through SEBI’s SCORES platform at www.scores.sebi.gov.in.

Step 3: If the client remains dissatisfied with the outcome of the SCORES complaint, the client may consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in.

m) The Investment Adviser shall never ask for the client’s login credentials and OTPs for the client’s Trading Account, Demat Account and Bank Account. Never share such information with anyone including Investment Adviser.