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 OfficerName – 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.

Investor Charter

A. Vision and Mission Statements for investors


Invest with knowledge & safety


Every investor should be able to invest in the 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

  1. To enter into an agreement with the client providing all details including fee details, aspect of Conflict of interest disclosure, and maintaining the confidentiality of information.
  2. To do a proper and unbiased risk–profiling and suitability assessment of the client.
  3. To obtain registration with Know Your Client Registration Agency (KRA) and Central Know Your Customer Registry (CKYC).
  4. To conduct audits annually.
  5. To disclose the status of complaints on its website.
  6. To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers, and associated SEBI regional/local Office details on its website.
  7. To employ only qualified and certified employees.
  8. To deal with clients only from official numbers.
  9. 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
    • Sharing of agreement copy
    • Completing KYC of clients
  • Disclosure to Clients
    • To provide full disclosure about its business, affiliations, and compensation in the agreement.
    • To not access clients’ accounts or holdings for offering advice.
    • 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.
  • 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 complaint 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.
  • 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)


  1. Always deal with SEBI registered Investment Advisers.
  2. Ensure that the Investment Adviser has a valid registration certificate.
  3. Check for the SEBI registration number. Please refer to the list of all SEBI registered Investment Advisers which is available on the SEBI website at the following: link
  4. 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.
  5. 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 takes into account available investment alternatives.
  6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on the advice.
  7. Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
  8. 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 an Investment Adviser.
  9. Be vigilant in your transactions.
  10. Approach the appropriate authorities for the redressal of your doubts/grievances.
  11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.


  1. Don’t fall for stock tips offered under the pretext of investment advice.
  2. Do not provide funds for investment to the Investment Adviser.
  3. 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.
  4. Don’t fall prey to luring advertisements or market rumors.
  5. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
  6. Don’t take decisions just because of repeated messages and calls by Investment Advisers.
  7. Do not fall prey to limited-period discounts or other incentives, gifts, etc. offered by Investment advisers.
  8. Don’t rush into making investments that do not match your risk-taking appetite and investment goals.
  9. Do not share the login credentials and passwords of your trading and Demat accounts with the Investment Adviser.

Data for the month end – February 2023
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
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
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
Compliance Audit Status
Sr. No. Financial Year Comliance Audit Status Remarks, If Any
1 FY 2020-21 Conducted -
2 FY 2021-22 Conducted -
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.


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.


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.