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3one4Capital FME IFSC LLP (“3one4”) is committed to upholding the highest standards of transparency, accountability, and customer protection. Protecting the interests of financial consumers is a core objective of financial sector regulation and ensuring efficient and effective grievance redressal is a key component of this objective.
Inline with this, 3one4 has established this Complaint Handling and GrievanceRedressal Policy (“Policy”) to ensure a fair, transparent, and time-bound mechanism for addressing complaints and grievances received from consumers in connection with financial products and services offered by 3one4at the Gujarat International Finance Tec-City (GIFT IFSC).
ThisPolicy is prepared in accordance with the requirements set out in theInternational Financial Services Centres Authority (“IFSCA”) Circular on“Complaint Handling and Grievance Redressal by Regulated Entities in the IFSC”dated December 2, 2024 (“IFSCA Regulations”), and any other rules and regulations issued by the IFSCA.
The objective of this Policy is to:
(a) Establish a clear and structured framework for the receipt, handling, and resolution of consumer complaints and grievances;
(b) Ensure fair, transparent, and timely redressal of complaints;
(c) Strengthen consumer confidence and trust in 3one4’s operations; and
(d) Ensure compliance with applicable regulatory requirements under the IFSCA framework.
ThisPolicy applies to all complaints and grievances received from consumers (retail, non-retail and professional) of 3one4 in relation to its fund management entity(“FME”) in IFSC.
The following shall not be considered as complaints under this Policy:
(a) Anonymous complaints (except whistleblower complaints);
(b) Incomplete or vague complaints;
(c) Allegations without supporting documentation or evidence;
(d) Suggestions, feedback, or requests for guidance, explanation, clarification or information;
(e) Queries or references seeking only information or clarification on financial products or services of 3one4.
(f) Complaints unrelated to 3one4’s financial products or services; or
(g) Complaints relating to unregistered or unregulated activities falling outside the scope of 3one4’s authorised business activities.
(a) “Authority” means theInternational Financial Services Centres Authority.
(b) “Complaint” means an expression of dissatisfaction made by a consumer to 3one4 relating to financial products, services, staff, or complaint handling where a response or resolution is explicitly or implicitly expected; it excludes matters listed in the ‘Scope andApplicability’ of this Policy.
(c) “Complaint Redressal AppellateOfficer” or “CRAO” means a senior-level official, shall be at the level of or one level below a Key Managerial Personnel, designated to hear appeals.
(d) “Complaint Redressal Officer” or“CRO” means the employee designated by 3one4 to handle complaints.
(e) “Consumer” means a retail, non-retail or professional consumer as defined under IFSCA regulations and guidelines.
(f) “IFSCA Framework” shall mean the regulatory and compliance framework prescribed by the IFSCA under theInternational Financial Services Centres Authority Act, 2019, including all applicable regulations, circulars, guidelines, handbooks, and directions issued thereunder, as amended from time to time.
Role: Complaints Redressal Officer (CRO)
Officer Name: Mr. Alok Mhatre
Designation: Principal Officer
Contact Details (Email): alok@3one4capital.com
Complaint Redressal Appellate Officer (CRAO)
Given the organisational size and non-retail nature of the investor base, formal lodgement channels shall be restricted to secure written communication only. The FME does not havean online portal for this function at this time.
A Consumer must lodge a Complaint inwriting via one of the following official channels:
(a) OfficialEmail: Sent to the designatedCRO email address: alok@3one4capital.com.
(b) PhysicalMail: Sent to the FME’sregistered office address, in a sealed envelope, explicitly marked for theattention of the CRO.
All complaints must bespecific, signed (physically or digitally), and must include at least thefollowing details:
(a) Investor/Consumer Name and Scheme details.
(b) A clear, concise description of the grievance.
(c) The date the alleged event occurred.
(d) Supporting documentation or evidence.
3one4 intends to implement, as the scale andcomplexity of its operations increase, a structured online system to facilitatethe registration, tracking, and resolution of complaints in a transparent andefficient manner. All stakeholders will be notified by 3one4 upon suchimplementation.
(a) Receipt of Complaint
i. Complaints may be submitted by email,in writing, in accordance with this Policy.
ii. Upon receipt of the complaint, the CROshall acknowledge the complaint within three (3) working days.
(b) Assessment and Resolution
i. The CRO shall assess the complaint on its merits and may seek additional information or documentation from the complainant, if required.
ii. Complaints shall be resolved preferably within fifteen (15) days and in any case not later than thirty (30) days from the date of acknowledgment.
iii. In case of rejection of a complaint, the CRO shall communicate the reasons for rejection in writing to the complainant.
(c) Where the CRO is or was involved in the subject matter of Complaint, another officer will be designated by 3one4 to handle such Complaints.
This mechanism demandsstrict adherence to the following timeframes:
Action By: CRO
Time Limit: Within 3 Working Days of receipt.
Regulation Basis: Acceptance must be acknowledged in writing
Action By: CRO
Time Limit: Within 5 Working Days of receipt.
Regulation Basis: Rejection must be informed in writing with explicit reasons.
Action By: CRO
Time Limit: Not later than 30 Days of acceptance.
Regulation Basis: The Complaint will be either resolved or rejected with full written reasons
If for any reason the above timelines are not adhered to, the CRO must provide reasons for the same in writing to the satisfaction of the CRAO.
(a) If the complainant is dissatisfied with the decision of the CRO, they may file an appeal before the CRAO within twenty-one (21) days from the date of receipt of the CRO’s decision.
(b) The CRAO shall dispose of the appeal within thirty (30) days from the date of receipt and shall communicate the decision in writing to the complainant.
If the complainant remains dissatisfied after exhausting the internal appellate mechanism, they may file a complaint with the Authority at grievance-redressal@ifsca.gov.inwithin twenty-one (21) days from the date of receipt of the CRAO’s decision.
3one4 shall maintain electronic records of:
(a) Complaints received and processed;
(b) All correspondence exchanged with complainants;
(c) Documents examined and relied upon;
(d) Details of resolution or rejection of complaints; and
(e) Timelines and outcomes of complaint handling.
Such records shall be maintained for a minimum period of six (6) years from the date of disposal of the complaint, or for a longer period if required in connection with any pending legal proceedings.
(a) 3one4 shall file periodic reports on complaint handling with the Authority, in such form and manner as may be prescribed under the IFSCA Framework.
(b) This Policy, including the names and contact details of the CRO and CRAO, shall be published on 3one4’s website under a dedicated ‘Complaint Handling and Grievance Redressal’ section.
The compliance officer shall be responsible for ensuring that all complaint handling and grievance redressal processes are in compliance with applicable regulatory requirements and internal policies. Any instances of non-compliance shall be promptly escalated to senior management for appropriate action.
ThisPolicy shall be reviewed at least annually and may be amended from time to time to ensure continued compliance with applicable laws, regulations, and internal governance requirements.
ThisPolicy has been approved by 3one4 Capital on January 10, 2025.
For any queries / concerns regarding the Conflict-of-Interest Policy, please write an email to partners@3one4capital.com.