Fund Selection & Portfolio Review Policy

Sanriya Finvest Pvt. Ltd. · ARN-193359 · AMFI Registered Mutual Fund & Specialised Investment Fund (SIF) Distributor

The objective of this policy is to ensure investor-first, consistent and auditable scheme selection, in line with the SEBI Master Circular for Mutual Funds and the AMFI Code of Conduct and Due Diligence framework. Sanriya Finvest aims to identify suitable products, disclose the associated risks and costs transparently, and maintain documentary evidence supporting every scheme presented to an investor.

This policy applies to all employees, EUIN holders and sub-distributors (if applicable) of Sanriya Finvest Pvt. Ltd. who:

• Present or distribute mutual fund schemes – equity, hybrid, debt, liquid, ELSS, index funds and ETFs, etc.
• Portfolio reviews or model portfolios.
• Engage with investors for PMS or other permitted products through authorised partners, subject to the additional regulatory restrictions applicable to those products.

Three principles govern how we select:

• Evidence-based decisions are preferred over emotion-based ones.
• Markets move in cycles, and portfolios must be reviewed as those cycles change.
• Risk sits at the centre of every portfolio choice, not at its edge.
• Working from these, we aim to help investors build wealth steadily, limit avoidable capital erosion during downturns, ensure every scheme in a portfolio serves a clear purpose, and communicate proactively – particularly in volatile markets.

• Only SEBI-registered AMCs and purchase-enabled schemes.
• A minimum one- to three-year track record. NFO if needed.
• Transactions are routed through recognised platforms — NSE NMF II, MFU or AMC/RTA portals — with EUIN captured on every transaction.

Schemes are shortlisted and presented through a structured evaluation process that combines quantitative analysis with qualitative assessment. The objective is to help investors make informed decisions based on suitability rather than past returns alone.

• The scheme's investment objective and category, and whether it aligns with your recorded risk profile.
• Performance across different market cycles, compared with its benchmark and peer category, without implying or assuring future returns.
• Risk-adjusted returns and the scheme's volatility relative to its category.
• The size of the scheme, portfolio quality and liquidity, and for debt schemes, the underlying credit quality.
• The experience and tenure of the fund manager, along with the track record of the Asset Management Company (AMC).
• The scheme's Riskometer, expense ratio, exit load, and lock-in period, wherever applicable.
• Information is sourced from publicly available and reliable data, and investors are encouraged to independently review and compare the same before investing.
• Suitability is assessed based on your risk profile, investment horizon, financial goals, intended asset allocation, and the relevant scheme category within your portfolio.
• Any other relevant qualitative or quantitative factors that may materially affect the suitability of a scheme may also be considered.

Schemes under SEBI or AMFI observation, schemes restricted or suspended for transactions, and schemes carrying a segregated portfolio are excluded from the shortlist.

We distribute:

• SEBI-registered mutual funds and SIF across equity, debt, hybrid and liquid categories.
• Schemes from AMCs whose processes are transparent and repeatable.
• AIF, PMS and other permitted products through authorised partners.
• We do not distribute: direct equity or derivatives; unregulated, opaque or illiquid products.
• If we would not place our own family's money in it, we do not put it in front of an investor.

• Sanriya Finvest Pvt. Ltd. is an AMFI-registered Mutual Fund Distributor and provides distribution services. Any guidance we offer is incidental to the distribution of the products we distribute and is provided without any separate fee or consideration, as permitted for mutual fund distributors.
• Investors are expected to review all product-related information before proceeding with a transaction. All investment decisions are made at the discretion of the investor.

• Sanriya Finvest does not have any ownership or affiliation with any Asset Management Company.
• Scheme selection is based on defined parameters and is not influenced by commissions or incentives.
• Commission earned from product providers is disclosed on the Commission Disclosure page.

Records relating to investor profiling, transactions and communications are maintained in accordance with applicable regulatory requirements and are available to the investor on request.

This is not a promise of high returns, and it is not a static document. It is a living guide that helps us stay rational when markets are not. Its purpose is to manage risk sensibly, pursue growth appropriate to each investor, and keep every decision rooted in care rather than convenience.

This policy is reviewed periodically, and on any change in the applicable regulatory guidelines. It is a working framework rather than a fixed prescription, and any investor may request a walkthrough of it during a review, or at any point when they feel uncertain.

• A valuation statement is sent to you every month.
• A portfolio review is offered at least once every twelve months, in person or through a video meeting, and the discussion is recorded.
• The review covers how the schemes you hold have performed, whether your circumstances or your risk profile have changed, and whether any holding needs your attention.
• Any change to a holding is made only on your instruction. We do not switch, redeem or rebalance a portfolio on our own.
• No assured, guaranteed or indicative return is promised at any review, and the maximum rate of return assumed in any illustration we prepare is 12% per annum.

• Investments are not equivalent to bank deposits. They are not obligations of, nor are they guaranteed or insured by, any government or insurance company unless explicitly stated otherwise. Past performance is not indicative of future results, and the value of investments may rise or fall.
• Mutual fund investments are subject to market risks. Please read all scheme-related documents carefully before investing. All investment applications are subject to the specific terms and conditions of the respective products.
• Sanriya Finvest Pvt. Ltd. is an AMFI-registered Mutual Fund Distributor (ARN-193359) and an APMI-registered PMS Distributor (APRN-01056). No indicative or assured returns are offered.