Hubridge

Cancellation and Refund Policy

If you decide to cancel the subscription anytime during the first 3 months of subscription, we will only charge for the first 3 months. Please write to support@hubridge.in requesting cancellation.

You can avail this facility only once per PAN (including close family members). If you subscribe again, the same facility will not be available.

You can cancel your subscription anytime after the first 3 months. However, no refunds are applicable for the ongoing month, once the invoice has been raised and paid.

For further queries, please write to support@hubridge.in.

Code of Conduct

Statement of General Policy

This Code of Ethics ("Code") has been adopted by Pavan Kumar Manchiraju and is designed to comply with the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 [sub-regulation (9) of regulation 15].

This Code establishes rules of conduct for all employees of Pavan Kumar Manchiraju and is designed to, among other things, to govern personal securities trading activities in the accounts of employees, immediate family/household accounts, and accounts in which an employee has a beneficial interest. The Code is based upon the principle that Pavan Kumar Manchiraju and his employees owe a fiduciary duty to Pavan Kumar Manchiraju's clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm, and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility

and responsibility. The Code is designed to ensure that the high ethical standards long maintained by Pavan Kumar Manchiraju continue to be applied. The purpose of the Code is to preclude activities that may lead to or give the appearance of conflicts of interest, insider trading, or other forms of prohibited or unethical business conduct. The excellent name and reputation of Pavan Kumar Manchiraju continue to be a direct reflection of the conduct of each employee.

Pursuant to the Investment Advisers Regulation, both Pavan Kumar Manchiraju and his employees are prohibited from engaging in fraudulent, deceptive, or manipulative conduct. Compliance with this section involves more than acting with honesty and good faith alone. It means that Pavan Kumar Manchiraju has an affirmative duty of utmost good faith to act solely in the best interest of his clients.

Pavan Kumar Manchiraju and his employees are subject to the following specific fiduciary obligations when dealing with clients:

The duty to have a reasonable, independent basis for the investment advice provided;
The duty to ensure that investment advice is suitable for meeting the client’s individual objectives, needs, and circumstances;
A duty to be loyal to clients.

By accessing the Website and/or Platform, You consent to be bound by this Privacy Policy and are accepting in meeting fiduciary responsibilities to his clients, Pavan Kumar Manchiraju expects every employee to demonstrate the highest standards of ethical conduct for continued employment with Pavan Kumar Manchiraju. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with Pavan Kumar Manchiraju. Employees are urged to seek the advice of Pavan Kumar Manchiraju, the investment advisor, for any questions about the Code or the application of the Code to their individual circumstances. Employees should also understand that a material breach of the provisions of the Code may constitute grounds for disciplinary action, including termination of employment with Pavan Kumar Manchiraju

The provisions of the Code are not all-inclusive. Rather, they are intended as a guide for employees of Pavan Kumar Manchiraju in their conduct. In those situations where an employee may be uncertain as to the intent or purpose of the Code, he/she is advised to consult with Pavan Kumar Manchiraju, and he may grant exceptions to certain provisions contained in the Code only in those situations when it is clear beyond dispute that the interests of our clients will not be adversely affected or compromised.

Code of Conduct for Investment Advisor

1.Honesty and fairness

An investment adviser shall act honestly, fairly, and in the best interests of its clients and in the integrity of the market.

2. Diligence

An investment adviser shall act with due skill, care, and diligence in the best interests of its clients and shall ensure that its advice is offered after thorough analysis and taking into account available alternatives.

3.Capabilities

An investment adviser shall have and effectively employ appropriate resources and procedures that are needed for the efficient performance of its business activities.

4. Information about clients

An investment adviser shall seek from its clients, information about their financial situation, investment experience, and investment objectives relevant to the services to be provided and maintain confidentiality of such information.

5. Information to its clients

An investment adviser shall make adequate disclosures of relevant material information while dealing with its clients.

6. Fair and reasonable charges

An investment adviser advising a client may charge fees, subject to any ceiling that may be specified by the board, if any. The investment adviser shall ensure that fees charged to the clients are fair and reasonable.

7. Conflicts of interest

An investment adviser shall try to avoid conflicts of interest as far as possible, and when they cannot be avoided, it shall ensure that appropriate disclosures are made to the clients and that the clients are fairly treated.

8. Compliance

An investment adviser, including its representative(s), shall comply with all regulatory requirements applicable to the conduct of its business activities so as to promote the best interests of clients and the integrity of the market.

9. Responsibility of management

The management of a proprietorship firm that is registered as an investment adviser shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures by the firm.

Disclosure – Pavan Kumar Manchiraju

The particulars given in this Disclosure Document have been prepared in accordance with SEBI (Investment Advisers) Regulations, 2013. The purpose of the Document is to provide essential information about the Investment Advisory Services in a manner to assist and enable the prospective client in making an informed decision for engaging Investment Advisor.

For the purpose of this Disclosure Document, Investment Adviser is with the Securities and Exchange Board of India as an Investment Advisor under SEBI (Investment Advisers) Regulations, 2013 vide registration no. INA000018975 dated 22/03/2024 having its registered office at Flat 1001, Tower - 5, Urbana BNRI Complex, Anandapur, KOLKATA, 700107, India.

A. Description about Pavan Kumar Manchiraju

History, Present Business and Background: In the capacity as adviser, Pavan Kumar Manchiraju aligns his interests with those of the client and seeks to provide the best suited advice based on client’s risk profile. He first tries to understand the client's return expectations, risk taking ability and goals, which in turn helps to arrive at an asset allocation suitable for the client.

Terms & Conditions for Advisory Services: Advisory services may include buying and selling the securities for an agreed fee structure for a defined time period, which may vary. The detailed terms and conditions are as per the agreement executed between client and Pavan Kumar Manchiraju.

B. Disciplinary History

No action has been taken against the Individual as an Investment Adviser by any regulator.

C. Investment Advisory Audits

Disclosure with respect to compliance with annual audit requirements under Regulation 19(3) of SEBI IA Regulations for last and current financial year has been made. No other affiliations or intermediary registrations exist.

D. Consideration Disclosure

Pavan Kumar Manchiraju does not receive or expect to receive any consideration in the form of remuneration, compensation, or otherwise for distribution or execution services from the issuers of securities advised.

E. Stock Broker/Intermediary Referral Disclosure

Does not recommend services of any stock broker or intermediary to clients.
No commission sharing agreement exists with any intermediary for recommending services.

F. Personal Holdings Disclosure

Not registered as a broker with SEBI and not actively engaged in proprietary trading. May invest in securities in the future.

G. Conflict of Interest Disclosure

No conflict of interest exists. No engagement in stock broking, depository, research, portfolio management or mutual fund distribution.

H. Product/Security Disclosure

Clients are advised to read key features, performance track record, and disclaimers of products on platforms like sebi.gov.in, nseindia.com, or bseindia.com before investing.

I. Disclaimers in Product Documents

Clients will be made aware of all disclaimers, warnings, and product-specific risks in materials used by the adviser.

J. Standard Risk Factors

Investments are subject to market risks; no assurance of achieving objectives.
Past performance is not indicative of future results.
Government policy, economic factors, and liquidity can affect portfolio value.
Investments may be affected by global factors, economic policies, and force majeure events.
Product names and nature do not reflect returns or safety.
Debt instruments involve reinvestment, default, and interest rate risks.
Unlisted securities expose investors to liquidity risks.
Derivatives entail pricing, leverage, and correlation risks.
Settlement periods and NAV changes can affect returns.
Low-rated instruments may increase portfolio risk.

K. General Risk

Clients are advised to thoroughly review all documents and risks before acting on advice. Adviser shall maintain confidentiality of all client data unless disclosure is required by law.

L. Investor Services

Contact Person: Pavan Kumar Manchiraju
Designation: Advisor
Address: Flat 1001, Tower - 5, Urbana BNRI Complex, Anandapur, KOLKATA, 700107
Email: pavan.m@hubridge.in

Clients may email complaints to: pavan.m@hubridge.in