Investor Greivance Policy
East72 Capital Fund 1
Date: October 1, 2025
Version: 1.1
1. INTRODUCTION
East72 Capital Fund 1 (“Fund”) is the first scheme of East72 Capital Trust (“Trust”) which is registered with SEBI as a category III Alternative Investment Fund (“AIF”) vide registration number IN/AIF3/24-25/1695. The Fund is an open-ended fund and is managed by the East72 Capital Management and Advisors LLP (“IM”).
2. PURPOSE & APPLICABILITY
This Policy establishes a transparent, efficient, and structured mechanism for receiving, addressing, and redressing investor complaints and grievances by the IM, in compliance with the SEBI (Alternative Investment Funds) Regulations, 2012 and other applicable circulars issued by SEBI.
3. GRIEVANCE
A grievance refers to any written or verbal expression of dissatisfaction raised by an investor relating to: compliance with terms outlined in the Private Placement Memorandum (PPM) or Contribution Agreement, delays or deficiencies in processing drawdowns, distributions, redemptions, transfers, or KYC, misstatements or inaccuracies in investor reporting, disclosures, NAV, or valuations, non-receipt or delay in communication or payouts. Any other matter as may be specified by SEBI from time to time. Grievances do not include general feedback, service suggestions, or matters governed by other regulatory bodies or courts.
4. ROLES & RESPONSIBILITIES
Oversight Matrix
Role: Grievance Redressal Officer (GRO)
Responsibility: Primary point of contact for receiving, acknowledging, and resolving investor complaints. Responsible for maintaining grievance records and updating SEBI’s SCORES platform.
Designated Partner: Vatsal Manish Gupta
Role: Compliance Oversight
Responsibility: Ensures adherence to SEBI (AIF) Regulations and timely reporting of grievances to the Board, SEBI, and Designated Bodies. Monitors implementation of this Policy.
Designated Partner: Nandan Satish Madhiwalla
In case of conflict or absence, responsibilities shall be carried out by any other available partner.
5. GRIEVANCE REDRESSAL PROCESS
A. Through IM
The investors shall first take up their grievances for redressal with the IM. Investors can contact IM for any grievances or complaints using the contact details mentioned below:
Email ID: compliance@east72capital.com
Mobile No.: 9825063757
Letter: 501, Puniska House, C. J. Marg, Off. Ambali-Bopal Road, Ahmedabad - 380054, Gujarat, India
Availability: Monday to Friday, 10:00 AM to 6:00 PM IST
The IM shall aim to redress investor grievances and complaints within 21 calendar days from the date of receipt of the grievance or complaint.
B. Through SCORES
If the grievance or complaint remains unresolved within 21 days and/or the investors are not satisfied with the resolution given by the IM, they can lodge their grievance by registering themselves on the SEBI Complaint Redressal System (SCORES) portal at www.scores.gov.in within a period of one year from the date of occurrence of the cause of action (i.e., rejection of the complaint, non-receipt of any communication, or if the reply/redressal received is not satisfactory).The IM shall redress investor grievances and complaints and upload the Action Taken Report (“ATR”) on SCORES within 21 calendar days from the date of receipt of the grievance or complaint through SCORES. Process to Register a Complaint on SCORES: Investors who wish to lodge a complaint on SCORES (complainant) are required to register themselves on www.scores.gov.in. While filing the registration form, details like Name of the investor, Permanent Account Number (PAN), contact details, email ID, etc. are required to be provided for effective communication and speedy redressal of the grievances. Upon successful registration, a unique user ID and a password shall be generated and communicated through an acknowledgement email to the complainant. If the grievance is not redressed satisfactorily, the investors may, in accordance with the SCORES guidelines, escalate the same through the SCORES Portal in accordance with the process laid out therein.
C. Through Online Resolution of Disputes (SMART ODR Portal)
After exhausting all options for resolution of the grievance, if the investors are still not satisfied with the outcome, or in cases where the issues raised require adjudication on any third-party rights, on questions of law or fact, or which is in the nature of a lawsuit between parties, they can initiate dispute resolution through the Online Dispute Resolution Mechanism (“ODR”) offered by SEBI through the Smart ODR Portal on the website https://smartodr.in/login.ODR has three levels of resolutions: pre-conciliation, conciliation, and arbitration, in accordance with the procedure specified by the Board. Such complaints shall then be resolved in accordance with the ODR Guidelines issued by SEBI from time to time.D. Additional Legal OptionsIn addition, investors have the option to approach legal forums including civil courts, consumer courts, etc.
6. MONITORING & REPORTING
The IM shall maintain data on investor complaints and compile the same on a quarterly basis within 7 days from the end of the quarter in the format prescribed by SEBI from time to time.
7. REVIEW AND UPDATE OF POLICY
The policy will be reviewed by the compliance officer annually or as required due to regulatory changes. Any material changes shall be approved by the Partners of the Investment Manager.