Regulatory & Legal
Name of the Investment Adviser: Modulor Advisory Services | Type of Registration: Non-Individual | Registration Number: INA100015115 | Validity of registration: Perpetual | Complete address with telephone numbers: Modulor Advisory Services, Plot No 139, Phase 2, Industrial Area Chandigarh- 160002, CHANDIGARH | Contact details of the Principal Officer: Name – Sanjit Singh Paul | Contact number – +91 98140 16978 | Email id – sanjit[at]modulorcapitlal[dot]com | Corresponding SEBI regional/local office address: Securities and Exchange Board of India, SCO 127-128, First Floor, Sector 17C, Chandigarh – 160017, CHANDIGARH.
SERI Regn. No. : INA100015115 (Click here to verify on the SEBI website).
BSE ASL Regn. No. : 2129 (Click here to download the list from the BSE ASL website).
Investor Charter
A. Vision and Mission Statements for investors
- Vision
Invest with knowledge & safety. - Mission
Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.
B. Details of business transacted by the Investment Adviser with respect to the investors
- To enter into an agreement with the client providing all details including fee details, aspect of Conflict of interest disclosure and maintaining confidentiality of information.
- To do a proper and unbiased risk – profiling and suitability assessment of the client.
- To obtain registration with Know Your Client Registration Agency (KRA) and Central Know Your Customer Registry (CKYC).
- To conduct audit annually.
- To disclose the status of complaints in its website.
- To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI regional/local Office details in its website.
- To employ only qualified and certified employees.
- To deal with clients only from official number.
- To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.
C. Details of services provided to investors (No Indicative Timelines)
Onboarding of Clients
o Sharing of agreement copy
o Completing KYC of clients
Disclosure to Clients
o To provide full disclosure about its business, affiliations, compensation in the agreement.
o To not access client’s accounts or holdings for offering advice.
o To disclose the risk profile to the client.
To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.
D. Details of grievance redressal mechanism and how to access it
- In case of any grievance / complaint, an investor should approach the concerned Investment Adviser and shall ensure that the grievance is resolved within 30 days.
2. If the investor’s complaint is not redressed satisfactorily, one may lodge a complaint with SEBI on SEBI’s ‘SCORES’ portal which is a centralized web based complaints redressal system. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates tracking the status of the complaint.
3. With regard to physical complaints, investors may send their complaints to:
Office of Investor Assistance and Education,
Securities and Exchange Board of India,
SEBI Bhavan, Plot No. C4-A, ‘G’ Block,
Bandra-Kurla Complex, Bandra (E),
Mumbai – 400 051.
E. Expectations from the investors (Responsibilities of investors)
- Do’s
- Always deal with SEBI registered Investment Advisers.
- Ensure that the Investment Adviser has a valid registration certificate.
- Check for SEBI registration number.
- Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.
- Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
- Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
- Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
- Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
- Be vigilant in your transactions.
- Approach the appropriate authorities for redressal of your doubts / grievances.
- Inform SEBI about Investment Advisers offering assured or guaranteed returns.
- Don’ts
- Don’t fall for stock tips offered under the pretext of investment advice.
- Do not provide funds for investment to the Investment Adviser.
- Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don’t let greed overcome rational investment decisions.
- Don’t fall prey to luring advertisements or market rumors.
- Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
- Don’t take decisions just because of repeated messages and calls by Investment Advisers.
- Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
- Don’t rush into making investments that do not match your risk taking appetite and investment goals.
- Do not share login credential and password of your trading and demat accounts with the Investment Adviser.
Data for the month end
| Month Ending - December 2025 | |||||||
| Sr No | Received from | Pending at the end of last month | Received | Resolved* | Total Pending # | Pending complaints > 3months | Average Resolution time^ (in days) |
| 1 | Directly from Investors | 0 | 0 | 0 | 0 | 0 | 0 |
| 2 | SEBI (SCORES) | 0 | 0 | 0 | 0 | 0 | 0 |
| 3 | Other Sources (if any) | 0 | 0 | 0 | 0 | 0 | 0 |
| Grand Total | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
^ Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by the total number of complaints resolved in the current month.
The trend of monthly disposal of complaints
| Sr. No | Month | Carried forward from previous month | Received | Resolved* | Pending# |
| 1 | September 2020 | 0 | 0 | 0 | 0 |
| 2 | October 2020 | 0 | 0 | 0 | 0 |
| 3 | November 2020 | 0 | 0 | 0 | 0 |
| 4 | December 2020 | 0 | 0 | 0 | 0 |
| 5 | January 2021 | 0 | 0 | 0 | 0 |
| 6 | February 2021 | 0 | 0 | 0 | 0 |
| 7 | March 2021 | 0 | 0 | 0 | 0 |
| 8 | April 2021 | 0 | 0 | 0 | 0 |
| 9 | May 2021 | 0 | 0 | 0 | 0 |
| 10 | June 2021 | 0 | 0 | 0 | 0 |
| 11 | July 2021 | 0 | 0 | 0 | 0 |
| 12 | August 2021 | 0 | 0 | 0 | 0 |
| 13 | September 2021 | 0 | 0 | 0 | 0 |
| 14 | October 2021 | 0 | 0 | 0 | 0 |
| 15 | November 2021 | 0 | 0 | 0 | 0 |
| 16 | December 2021 | 0 | 0 | 0 | 0 |
| 17 | January 2022 | 0 | 0 | 0 | 0 |
| 18 | February 2022 | 0 | 0 | 0 | 0 |
| 19 | March 2022 | 0 | 0 | 0 | 0 |
| 20 | April 2022 | 0 | 0 | 0 | 0 |
| 21 | May 2022 | 0 | 0 | 0 | 0 |
| 22 | June 2022 | 0 | 0 | 0 | 0 |
| 23 | July 2022 | 0 | 0 | 0 | 0 |
| 24 | August 2022 | 0 | 0 | 0 | 0 |
| 25 | September 2022 | 0 | 0 | 0 | 0 |
| 26 | October 2022 | 0 | 0 | 0 | 0 |
| 27 | November 2022 | 0 | 0 | 0 | 0 |
| 28 | December 2022 | 0 | 0 | 0 | 0 |
| 29 | January 2023 | 0 | 0 | 0 | 0 |
| 30 | February 2023 | 0 | 0 | 0 | 0 |
| 31 | March 2023 | 0 | 0 | 0 | 0 |
| 32 | April 2023 | 0 | 0 | 0 | 0 |
| 33 | May 2023 | 0 | 0 | 0 | 0 |
| 34 | June 2023 | 0 | 0 | 0 | 0 |
| 35 | July 2023 | 0 | 0 | 0 | 0 |
| 36 | August 2023 | 0 | 0 | 0 | 0 |
| 37 | September 2023 | 0 | 0 | 0 | 0 |
| 38 | October 2023 | 0 | 0 | 0 | 0 |
| 39 | November 2023 | 0 | 0 | 0 | 0 |
| 40 | December 2023 | 0 | 0 | 0 | 0 |
| 41 | January 2023 | 0 | 0 | 0 | 0 |
| 42 | February 2024 | 0 | 0 | 0 | 0 |
| 43 | March 2024 | 0 | 0 | 0 | 0 |
| 44 | April 2024 | 0 | 0 | 0 | 0 |
| 45 | May 2024 | 0 | 0 | 0 | 0 |
| 46 | June 2024 | 0 | 0 | 0 | 0 |
| 47 | July 2024 | 0 | 0 | 0 | 0 |
| 48 | August 2024 | 0 | 0 | 0 | 0 |
| 49 | September 2024 | 0 | 0 | 0 | 0 |
| 50 | October 2024 | 0 | 0 | 0 | 0 |
| 51 | November 2024 | 0 | 0 | 0 | 0 |
| 52 | December 2024 | 0 | 0 | 0 | 0 |
| 53 | January 2025 | 0 | 0 | 0 | 0 |
| 54 | February 2025 | 0 | 0 | 0 | 0 |
| 55 | March 2025 | 0 | 0 | 0 | 0 |
| 56 | April 2025 | 0 | 0 | 0 | 0 |
| 57 | May 2025 | 0 | 0 | 0 | 0 |
| 58 | June 2025 | 0 | 0 | 0 | 0 |
| 59 | July 2025 | 0 | 0 | 0 | 0 |
| 60 | August 2025 | 0 | 0 | 0 | 0 |
| 61 | September 2025 | 0 | 0 | 0 | 0 |
| 62 | October 2025 | 0 | 0 | 0 | 0 |
| 63 | November 2025 | 0 | 0 | 0 | 0 |
| 64 | December 2025 | 0 | 0 | 0 | 0 |
| Grand Total | 0 | 0 | 0 | 0 |
*Inclusive of complaints of previous months resolved in the current month.
#Inclusive of complaints pending as of the last day of the month.
The trend of annual disposal of complaints
| Sr. No | Year | Carried forward from previous year | Received | Resolved* | Pending # |
| 1 | 2020-21 | 0 | 0 | 0 | 0 |
| 2 | 2021-22 | 0 | 0 | 0 | 0 |
| 3 | 2022-23 | 0 | 0 | 0 | 0 |
| 4 | 2023-24 | 0 | 0 | 0 | 0 |
| 5 | 2024-25 | 0 | 0 | 0 | 0 |
| 6 | 2025-26 | 0 | 0 | 0 | 0 |
| Grand Total | 0 | 0 | 0 | 0 |
*Inclusive of complaints of previous years resolved in the current year.
#Inclusive of complaints pending as of the last day of the year.
You can submit your grievance/complaints with us at services@modulorcapital.com
| Officers | ||||
| Sr. No. | Designation | Name | mobile | |
| 1 | Principal Officer | Sanjit Singh Paul | principal.officer[at]modulorcapital[dot]com | 9814406500 |
| 2 | Compliance Officer | Sanjit Singh Paul | compliance.officer[at]modulorcapital[dot]com | 9814406500 |
| 3 | Grievance Officer | Bhavish Sood | grievance.officer[at]modulorcapital[dot]com | 9646072422 |
Compliance Audit Status
| Sr. No. | Financial Year | Comliance Audit Status | Remarks, If Any |
| 1 | FY 2020-21 | Conducted | - |
| 2 | FY 2021-22 | Conducted | - |
| 3 | FY 2022-23 | Conducted | - |
| 4 | FY 2023-24 | Conducted | - |
| 5 | FY 2024-25 | Conducted | - |
Audit Reports are available on request. Please email to: compliance.officer[at]modulorcapital.com, for the specific year, along with proof of identity.
Conflict of Interest Disclosure
The investment adviser (firm), its partners, employees, staff, and their first relations are exposed to the same investment strategies advised to the clients of the firm. These include positions over mutual funds, stocks, and unlisted shares made in the individual and firm’s capacity as per their corresponding risk profile and investment objectives. All actions of buying and selling are conducted after bulk dissemination/ broadcast of strategy-level instructions to the clients at the same time through various channels.
DISCLAIMER
Registration granted by SEBI, membership of BASL (in case of IAs) and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. Investment in securities market are subject to market risks. Read all the related documents carefully before investing. The securities quoted are for illustration only and are not recommendatory.
Performance results are presented before fees, taxes, and execution costs and reflect the reinvestment of dividends and capital gains. Past performance may not be indicative of future results. Therefore, no current or prospective client should assume that the future performance of any specific investment, or investment strategy (including the investments and/or investment strategies recommended by the advisor), will be profitable or equal to past performance levels. Performance results represent the results of our model portfolios. The actual current performance of the portfolio may be lower or higher than the performance of the strategy. The returns for the strategy in certain years were significantly higher than the returns of its comparative benchmark index. These returns were the result of certain market factors and events that may not be replicated in the future. Style allocation in all portfolios will vary over time and may be changed at Modulor Advisory Service’s discretion. It is important to remember that there are risks inherent in any investment and that there is no assurance that any adviser, money manager, asset class, style, or index will provide positive performance over time.
All investment strategies have the potential for profit or loss. Changes in investment strategies, contributions, or withdrawals may materially alter the performance, strategy, and results of your portfolio. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client’s investment portfolio. Historical performance results for investment indexes and/or categories generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment-management fee, the incurrence of which would have the effect of decreasing historical performance results. Economic factors, market conditions, and investment strategies will affect the performance of any portfolio and there are no assurances that it will match or outperform any particular benchmark for measuring the performance of a portfolio. Depending upon the holdings in your portfolio, your investment objectives, and your risk temperament, it may be more appropriate to measure performance against a different benchmark. All performance results are unaudited and have not been independently verified. Information pertaining to Modulor Advisory Services’ advisory operations, services, and fees is set forth in Modulor Advisory Services’ current disclosure statement.
DISCLAIMER
Registration granted by SEBI, membership of BASL (in case of IAs) and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. Investment in securities market are subject to market risks. Read all the related documents carefully before investing. The securities quoted are for illustration only and are not recommendatory.
Performance results are presented before fees, taxes, and execution costs and reflect the reinvestment of dividends and capital gains. Past performance may not be indicative of future results. Therefore, no current or prospective client should assume that the future performance of any specific investment, or investment strategy (including the investments and/or investment strategies recommended by the advisor), will be profitable or equal to past performance levels. Performance results represent the results of our model portfolios. The actual current performance of the portfolio may be lower or higher than the performance of the strategy. The returns for the strategy in certain years were significantly higher than the returns of its comparative benchmark index. These returns were the result of certain market factors and events that may not be replicated in the future. Style allocation in all portfolios will vary over time and may be changed at Modulor Advisory Service’s discretion. It is important to remember that there are risks inherent in any investment and that there is no assurance that any adviser, money manager, asset class, style, or index will provide positive performance over time.
All investment strategies have the potential for profit or loss. Changes in investment strategies, contributions, or withdrawals may materially alter the performance, strategy, and results of your portfolio. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client’s investment portfolio. Historical performance results for investment indexes and/or categories generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment-management fee, the incurrence of which would have the effect of decreasing historical performance results. Economic factors, market conditions, and investment strategies will affect the performance of any portfolio and there are no assurances that it will match or outperform any particular benchmark for measuring the performance of a portfolio. Depending upon the holdings in your portfolio, your investment objectives, and your risk temperament, it may be more appropriate to measure performance against a different benchmark. All performance results are unaudited and have not been independently verified. Information pertaining to Modulor Advisory Services’ advisory operations, services, and fees is set forth in Modulor Advisory Services’ current disclosure statement.
TRADEMARKS
Modulor Capital®, Quantamental Investing®, PCR Triangle®, QVGS Galactic®, QVGS Continental®, QVGS Sapien®, and QVGS Butterfly® are the trademarks owned by the partners of Modulor Advisory Services.
Greviance Redressal Mechanism
Client’s queries/complaints may arise due to a lack of understanding or a deficiency of service experienced by clients. Deficiency of service may include a lack of explanation, clarification, or understanding, which escalates into shortfalls in the expected delivery standards, either due to inadequacy of facilities available or through the attitude of staff towards the client.
- In case of any complaint or query:
Please contact our compliance officer, Mr. Sanjit Singh Paul, email id – compliance.officer[at]modulorcapital.com and phone no +91- 9814406500
You may also approach CEO/ partner/ IA- Mr/ Mr. Sanjit Singh Paul, Email ID: principal.officer[at]modulorcapital.com and Phone No.- 9814406500
- In case you are not satisfied with our response, you can lodge your grievance with SEBI at https://scores.sebi.gov.in/, or you may also write to any of the offices of SEBI. SCORES may be accessed through the SCORES mobile application as well, same can be downloaded from link below:
https://play.google.com/store/apps/details?id=com.ionicframework.sebi236330
ODR Portal could be accessed if unsatisfied with the response. Your attention is drawn to the SEBI circular no. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023, on “Online Resolution of Disputes in the Indian Securities Market”. A common Online Dispute Resolution Portal (“ODR Portal”), which harnesses conciliation and online arbitration for the resolution of disputes arising in the Indian Securities Market, has been established. ODR Portal can be accessed via the following link – https://smartodr.in/
Escalation Matrix
| Details of designation | Contact Person Name | Address where the physical address location | Contact No. | Email-ID | Working hours when complainant can call |
| Customer Care | - | Plot No. 139, Phase II, Industrial Area, Chandigarh - 160002. INDIA. | 9814016978 | services[at]modulorcapital.com | 11 am to 5 pm - Monday to Friday, except exchange holidays. |
| Bhupinder Paul Singh | grievance.officer[at]modulorcapital.com | ||||
| Head of Customer Care | |||||
| Compliance Officer | Sanjit Singh Paul | 9814406500 | compliance.officer[at]modulorcapital.com | ||
| CEO | principal.officer[at]modulorcapital.com | ||||
| Principal Officer |
AML Policy
1. Objective
To establish a comprehensive framework for detecting, preventing, and reporting money laundering and terrorist financing activities, ensuring compliance with the PMLA, SEBI regulations, and other applicable laws.
2. Scope
This policy applies to all employees, clients, and operations of the Investment Advisory firm, covering all products and services offered.
3. Regulatory Framework
The policy is formulated in accordance with:
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Prevention of Money Laundering Act, 2002 (PMLA)
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SEBI Master Circular on AML and CFT obligations dated February 3, 2023
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SEBI Circular ISD/CIR/RR/AML/1/06 dated January 18, 2006
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SEBI Master Circular for Investment Advisers dated May 21, 2024
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Financial Action Task Force (FATF) Recommendations
4. Key Components
a. Customer Due Diligence (CDD) and Know Your Customer (KYC)
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Obtain and verify client identification documents as per SEBI guidelines.
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Identify and verify the beneficial owner(s) in case of non-individual clients.
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Conduct risk-based CDD, categorizing clients into low, medium, or high risk.
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Periodically update KYC information, especially for high-risk clients.
b. Risk Assessment
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Evaluate the risk associated with clients, products, services, and geographies.
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Implement enhanced due diligence for high-risk clients and transactions.
c. Monitoring and Reporting of Transactions
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Monitor all financial transactions to identify suspicious activities.
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Report the following to the Financial Intelligence Unit-India (FIU-IND):
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All cash transactions exceeding ₹10 lakhs or equivalent in foreign currency.
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Series of cash transactions integrally connected to each other within a month that aggregate to more than ₹10 lakhs.
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All suspicious transactions, irrespective of the amount involved.
-
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Maintain records of transactions and reports filed for a minimum of five years.
d. Appointment of Principal Officer and Designated Director
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Appoint a Principal Officer responsible for ensuring compliance with AML policies and procedures.
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Designate a Director on the Board as the ‘Designated Director’ to oversee the AML framework.
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Communicate the details of the Principal Officer and Designated Director to FIU-IND.
e. Employee Training and Awareness
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Conduct regular training programs for employees to educate them about AML laws, typologies, and red flags.
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Ensure that employees understand their roles and responsibilities in detecting and reporting suspicious activities.
f. Record Keeping
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Maintain and preserve records of client identification, account files, and business correspondence for at least five years after the business relationship ends.
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Ensure that records are readily available for inspection by regulatory authorities.
g. Internal Control and Audit
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Implement internal controls to ensure ongoing compliance with AML policies.
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Conduct periodic independent audits to assess the effectiveness of the AML framework.
5. Review and Updates
The AML policy should be reviewed annually or as and when there are significant changes in regulations or business operations. Updates should be approved by the Board of Directors and communicated to all relevant stakeholders.
6. Conclusion
Adherence to this AML policy will help in mitigating the risk of money laundering and terrorist financing, ensuring the integrity of the financial system, and maintaining the firm’s reputation.
Grievance Redressal Mechanism (for Accessibility Issues)
In compliance with the SEBI circular, Modulor Advisory Services has established a dedicated grievance redressal mechanism to address accessibility-related complaints from persons with disabilities (PwDs).
- Dedicated Channels
- Email: accessibility@modulorcapital.com
- Helpline: +91-9814016978 (operational Mon–Fri, 11:00 AM – 5:00 PM)
- Web Form: Available on http://www.modulorcapital.com/accessibility
- Process
- All accessibility-related grievances will be acknowledged within 2 working days.
- Resolution/response will be provided within 15 working days.
- Complex issues requiring longer timelines will be communicated clearly to the complainant.
- Escalation Matrix
- Level 1: Nodal Officer (Mr. Bhupinder Paul Singh, Email: nodal.officer[at]modulorcapital.com, Contact: +91-9814016978)
- Level 2: Partner (Sanjit Singh Paul, Email: sanjit[at]modulorcapital.com, Contact: +91-9814406500)

