Conflict of Interest Policy
How we identify, disclose and manage actual or potential conflicts of interest — so that every recommendation is made in the investor’s best interest.
INVININD WEALTH (OPC) PRIVATE LIMITED
CFP® | AMFI-registered Mutual Fund Distributor
ARN-291417 | EUIN: E547755 | cs@invinind.com
Pursuant to SEBI (Mutual Funds) Regulations 1996, AMFI Code of Conduct for Intermediaries, and SEBI Circular dated 22 October 2021
Effective Date: 1 April 2025 Last Reviewed: April 2026
1. Purpose & Scope
This Conflict of Interest Policy (‘Policy’) sets out the framework adopted by INVININD WEALTH (OPC) PRIVATE LIMITED (‘the Firm’) to identify, disclose, and manage actual or potential conflicts of interest that may arise in the course of providing mutual fund distribution services to investors. This Policy applies to all principals, employees, and representatives of the Firm.
2. What Is a Conflict of Interest?
A conflict of interest arises when the Firm’s personal, financial, or business interests — or those of its associates — have the potential to influence, or may appear to influence, the advice or recommendations made to an investor in a manner that is not in the investor’s best interest.
3. Identified Potential Conflicts of Interest
The following conflicts have been identified in the context of the Firm’s operations:
| Conflict | Description | How Managed |
|---|---|---|
| Commission-Based Compensation | The Firm earns trail commission from AMCs based on AUM of schemes held by investors. Higher-commission schemes could be recommended over better-suited alternatives. | Scheme recommendations are based solely on investor suitability, risk profile, and financial goals. Commission rates are never a criterion for scheme selection. |
| AMC Empanelment & Relationships | The Firm has business relationships with multiple AMCs through ARN empanelment. This could create a bias toward empanelled AMC products. | The Firm recommends schemes across all empanelled AMCs and does not favour any AMC. Investors may request a full list of empanelled AMCs at any time. |
| Regular vs. Direct Plan | Recommending Regular Plans (which carry trail commission) over Direct Plans (which have lower TER and no distributor commission) benefits the Firm financially. | Investors are informed of the difference between Regular and Direct Plans. Mutual funds offer Direct Plans which are exclusive of any distributor brokerage. Investors are at liberty to opt for Direct Plans offered by AMCs directly if they do not wish any brokerage to be paid to the distributor. The choice is disclosed transparently. |
| Referral Arrangements | The Firm may receive referral fees or non-monetary benefits from third-party service providers (e.g., insurance, loan partners). | Any such arrangement is disclosed to investors before a recommendation. The Firm does not recommend third-party products unless genuinely suitable for the investor. |
| Personal Investments | Principals of the Firm may hold personal investments in mutual fund schemes recommended to investors. | Personal investment decisions are independent of client recommendations. The Firm follows the CFP® Code of Ethics, which prohibits self-dealing. |
| Director's Outside Business Interest — Global Investing | The Founder Director is, in his individual capacity, registered as a channel partner of Kristal.AI (whose Indian entity, Kristal Advisors Pvt. Ltd., is a SEBI-registered Investment Adviser — INA100014569). Any referral compensation from this arrangement accrues to him personally, not to the Firm. This interest could influence conversations with the Firm's investors. | This activity is conducted separately from, and not under, the Firm's AMFI registration (ARN-291417) or on the Firm's platforms. Any introduction to Kristal is made in the Director's individual capacity, with this relationship and compensation disclosed to the investor beforehand. The Firm's mutual fund recommendations remain governed solely by the investor's documented risk profile and suitability. Investors are free to decline or approach any platform directly. |
4. Guiding Principles for Managing Conflicts
- Suitability First: All recommendations are based on the investor’s financial goals, risk profile, time horizon, and investment knowledge — as documented in the Investor Onboarding Form.
- Full Disclosure: All material conflicts of interest are disclosed to investors before any recommendation is made. This Policy is publicly accessible.
- CFP® Ethics: The Firm’s principals hold the CFP® certification and are bound by the Financial Planning Standards Board (FPSB) India Code of Ethics, which mandates acting in the client’s best interest at all times.
- AMFI Code of Conduct: The Firm adheres to the AMFI Code of Conduct for Mutual Fund Distributors, including fair dealing, transparency, and prohibition of mis-selling.
- No Churning: The Firm does not encourage unnecessary switching of schemes or portfolios for the purpose of generating additional commission.
- Investor Consent: Investors have the right to decline recommendations and invest independently in Direct Plans without any pressure or penalty.
5. Investor Rights
- Request a copy of this Policy and the Commission Disclosure Statement at any time.
- Ask for the specific commission earned by the Firm on any recommended scheme.
- Opt for Direct Plans at any time by approaching the AMC directly — Direct Plans carry no distributor brokerage.
- Lodge a complaint with AMFI (1800-266-7575) or SEBI (scores.sebi.gov.in / 1800-266-7575) if they believe this Policy has been violated.
- Escalate grievances to the Firm’s Compliance Officer at cs@invinind.com.
6. Policy Review
This Policy will be reviewed annually or whenever there is a material change in the Firm’s business model, regulatory requirements, or applicable SEBI/AMFI guidelines. The latest version will be published on this website and will supersede all previous versions.
INVININD WEALTH (OPC) PRIVATE LIMITED is committed to maintaining the highest standards of integrity, transparency, and investor protection. This Policy reflects our commitment to acting in the best interests of our investors at all times.
A copy of this policy is also available on request by writing to cs@invinind.com.