Overview

Assets Under Management: $2.0 billion
High-Net-Worth Clients: 28
Average Client Assets: $21.3 million

Frequently Asked Questions

AVENDUS WEALTH MANAGEMENT PRIVATE LIMITED is a fee-based investment advisor. Detailed fee schedules are available in their SEC Form ADV filing.

Yes. As an SEC-registered investment advisor (CRD #156771), AVENDUS WEALTH MANAGEMENT PRIVATE LIMITED is subject to fiduciary duty under federal law.

AVENDUS WEALTH MANAGEMENT PRIVATE LIMITED serves 28 high-net-worth clients according to their SEC filing dated February 09, 2026. View client details ↓

According to their SEC Form ADV, AVENDUS WEALTH MANAGEMENT PRIVATE LIMITED offers portfolio management for individuals, portfolio management for institutional clients, and selection of other advisors. View all service details ↓

AVENDUS WEALTH MANAGEMENT PRIVATE LIMITED manages $2.0 billion in client assets according to their SEC filing dated February 09, 2026.

According to their SEC Form ADV, AVENDUS WEALTH MANAGEMENT PRIVATE LIMITED serves high-net-worth individuals and institutional clients. View client details ↓

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection

Clients

Number of High-Net-Worth Clients: 28
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 29.76%
Average Client Assets: $21.3 million
Total Client Accounts: 461
Non-Discretionary Accounts: 461

Regulatory Filings

CRD Number: 156771
Filing ID: 2051634
Last Filing Date: 2026-02-09 11:50:52

Form ADV Documents

Primary Brochure: AWM PART 2 (2026-02-09)

View Document Text
Part 2A of Form ADV: Firm Brochure Item 1 – Cover Page Avendus Wealth Management Private Limited 901, Platina, 9th Floor, Plot No. C-59, Bandra Kurla Complex, Bandra (E), Mumbai-400 051, India Telephone: 91 22 6648 1295 Email: palak.furia@avendus.com Web Address: www.avendus.com Date of Brochure: Feb 10, 2026 this brochure, please contact us at 91 22 6648 1295 This brochure provides information about the qualifications and business practices of Avendus Wealth Management Private Limited. If you have any questions about the contents of or palak.furia@avendus.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Avendus Wealth Management Private Limited also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 156771. 1 Item 2 Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about advisory personnel of Avendus. Avendus believes that communication and transparency are the foundation of its relationship and continually strive to provide our Clients with complete and accurate information at all times. Avendus encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. And of course, we always welcome your feedback. Since our last disclosure document, there has been no material change. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Avendus. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. You may also request a copy of this Disclosure Brochure at any time, by contacting us at 91-22-6648- 1295 or by email at palak.furia@avendus.com. 2 Item 3: Table of Contents Particulars Page no. Item no 1 2 3 4 5 6 7 8 9 10 11 1 2 3 4 7 9 10 10 13 13 17 12 13 14 15 16 17 18 Cover Page Material Changes Table of Contents Advisory Business Fees and Compensation Performance-Based Fees and Side-By-Side Management Types of Clients Methods of Analysis, Investment Strategies and Risk of Loss Disciplinary Information Other Financial Industry Activities and Affiliations Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Brokerage Practices Review of Accounts Client Referrals and Other Compensation Custody Investment Discretion Voting Client Securities Financial Information Customary Privacy Policy Notice 18 19 19 20 20 21 21 22 3 Item 4 Advisory Business Avendus Wealth Management Private Limited (also referred to as the firm, we, us and Avendus Wealth Management throughout this disclosure brochure) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and headquartered in Mumbai, India. The firm caters to Investment Advisory and Portfolio Management needs of Family office and Ultra High Net Worth Individuals / families, spanning all asset classes. • Avendus Wealth Management is a subsidiary of Avendus Capital Private Limited. Although there are several individuals with direct ownership in Avendus Capital Private Limited, Redpoint Investments Pte Ltd holds around 62.76% in the total paid up share capital of the Avendus Capital Private Limited. Funding to Redpoint has been provided by funds managed by KKR Asian Fund II LP (KKR) and/or its affiliates. • Listed below are the three individuals with ownership and Directorship in Avendus Capital Private Limited. The following individuals’ ownership collectively around 16.47% and they are ultimately responsible for the day-to-day operations of Avendus Capital Private Limited and its subsidiaries. o Gaurav Deepak o Ranu Vohra o Kaushal Aggarwal • Avendus Wealth Management filed its initial application to register as an investment adviser in December 2012. Avendus Wealth Management acquired the investment adviser registration of its parent company, Avendus Capital Private Limited through a proper succession filing. Avendus Capital Private Limited deemed it appropriate to transfer its wealth management business into a separate subsidiary – Avendus Wealth Management effective December 1, 2012. DESCRIPTION OF ADVISORY SERVICES The following are descriptions of the primary advisory services of Avendus Wealth Management. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Avendus Wealth Management before we can provide you the services described below. Individual Portfolio Management Avendus Wealth Management offers portfolio management and investment advisory services, which involves Avendus Wealth Management providing you with regular and ongoing supervision over your specified accounts. You may appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”) to execute trades in the Account. The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical/demat custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The following accounts are opened by you: 4 • Portfolio Management Account with Avendus Wealth Management Private Limited • Bank Account with HDFC Bank Limited • Custody Account with HDFC Bank Limited • Equity Broking Account with Emkay Global Financial Services Ltd. • The client will give a limited Power of Attorney (POA) in favor of Avendus Wealth Management Private Limited to operate the Bank and Custody Account and to make investments on behalf of the client based on the instructions of the client to Avendus Wealth Management. The POA could be revoked by the client at any time. We monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. Through personal discussions in which goals and objectives based on your particular circumstances are established, we develop, create and manage a portfolio. During our data-gathering process, we determine your individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We based on your financial situation, investment objectives and risk tolerance then manage the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you periodically to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities, types of securities, or industry sectors. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit, and in fact, are required to not disclose such non-public information due to insider trading regulations. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., Ultra-Conservative, Conservative, Moderate, Balanced, Growth, and Aggressive). 5 Investment Advisory Services We may provide financial and investment consultations on accounts not managed or maintained by us. Accounts are reviewed based upon your specific needs and desires for future financial goals and/or objectives. Avendus Wealth Management provides general or specific recommendations to the client. The service provides regular consultations provided on a quarterly or more frequent basis. Through this service, we will not have any authority or responsibility to implement our recommendations. All final decisions to accept our advice and implement our advice are the responsibility of the client. If you have accounts reviewed by our firm and are unable to implement our investment recommendations, it is important to notify us so that we can properly adjust future recommendations. Clients are always responsible for notifying Avendus Wealth Management of any changes to their financial situation or investment objectives. We will meet with the client as often as needed to determine the client’s financial situation and investment objectives and to find out if the client would like to impose and/or modify any reasonable restrictions on their accounts. It is important that you understand that Avendus Wealth Management provides investment advice to other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you. We are not obligated in any way to recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. There can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit, and in fact, are required to not disclose such non-public information due to insider trading regulations. Limitation on Advice for Certain Types of Investments Our investment recommendations are not limited to any specific product or service offered by a broker- dealer and will generally include advice regarding the following Indian securities. • Equities (listed and unlisted) • Mutual Funds. • Futures and Options • Bonds • Structured Notes/ Products • Securities as defined under Securities Contract (Regulation) Act, 1956. Note – we do not generally provide advice on U.S. originated securities and investments. Therefore, we recommend you consult with other financial professionals for advice on U.S. investments. 6 Tailor Advisory Services to Individual Needs of Clients Avendus Wealth Management’s advisory services are always provided based on your individual needs. This means, for example, that when we provide portfolio management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors primarily under the non-discretionary services. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Clients Assets Managed by Avendus Wealth Management As of 3/ 31/2025 we were actively managing total client assets of $ 2,005,861,520 on a non- discretionary basis. Item 5 Fees and Compensation In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding our firm’s services along with descriptions of each service’s fees and compensation arrangements. It should be noted that lower fees for comparable service may be available from other sources. The exact fees and other terms will be outlined in the agreement between you and Avendus Wealth Management. Fees for Individual Portfolio Management and for Investment Advisory Services Our annual fees for Portfolio Management and Investment Advisory Services are based upon a percentage of assets under management and generally range from 0.5 p.a. % to 2.50% p.a. in case of Investment Advisory Services and a maximum of 6% in case of Portfolio Management Services. Our fees are divided and billed, quarterly/monthly in arrears, at the end of each quarter based upon the average value (market value or fair market value in the absence of market value), of the client's account. Fees will be debited from the account in accordance with the client authorization in the Portfolio Management Agreement. A minimum of USD 61,000 (INR 5,000,000) of assets under management is required to work with our firm. This account size may be negotiable under certain circumstances. Avendus Wealth Management Private Limited may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee, subject to applicable laws. Compensation in Addition to Management/Advisory Fee. In addition to or in lieu of (for Advisory consulting services) our standard annual fee, we may also receive commissions on the execution of securities held in Portfolio Management accounts and Advisory accounts, subject to relevant regulations. Such commissions may be paid directly by the product sponsor or Mutual Fund Company to Avendus Wealth Management, subject to relevant regulations. You are never obligated to work with our firm and are never obligated to purchase investment products through our investment advisor representatives. You have the option to purchase investment products through other brokers or agents that are not affiliated with Avendus Wealth Management. 7 Performance Based Fees. In select situations, we may assess a performance-based fee arrangement in addition to the annual portfolio management fee. Note, we do not assess performance-based fees to all clients. Our performance-based fee schedule is based on a percentage of assets under management plus a percentage of the difference between a client's account and that of an appropriate pre-defined return. Avendus Wealth Management Private Limited will choose the pre-defined return based on the nature of the investment strategy to be used. The fees charged for this service will be determined by the client's individual circumstances and will never exceed 25% of the account's performance above an appropriate index/pre-defined return. The actual fees are disclosed to the client before entering into this type of arrangement and are detailed in the client's Portfolio Management Agreement and Investment Advisory Agreement. Performance Based Fees are billed on an Annual basis. The client must understand the proposed method of compensation and its risks prior to entering into the contract. Accordingly, clients paying performance-based fees are directed to the "Performance-Based Fees" section (Item 6) below for more comprehensive disclosures, including potential conflicts of interest resulting from this type of compensation. Clients who elect to terminate their contracts will be charged a performance-based fee based on the performance of the account for the measuring period going back from the termination date and pro-rated from the date on which the performance-based fee was previously assessed by our firm or the first transaction date, whichever is later. The performance-based fee may create an incentive for Avendus Wealth Management Private Limited to recommend investments, which may be riskier or more speculative than those, which would be recommended under a different fee arrangement. General Information Limited Negotiability of Fees: Although Avendus Wealth Management Private Limited has established the aforementioned fee schedule(s) we retain the discretion to negotiate alternative fees on a client-by- client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. We may group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the annualized fee. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. Termination of the Advisory Relationship: Either party, for any reason, may cancel a client agreement at any time. Upon termination of any account, any prepaid, unearned fees will be promptly refunded and outstanding fees or charges will be recovered from the client. However, it is not the policy of our firm to normally accept any prepaid fees. Mutual Fund Fees: All fees paid to Avendus Wealth Management Private Limited for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund 8 also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. As stated above, we may receive a portion of the loads and/or fees charged by mutual funds in the form of commissions. Wrap Fee Programs and Separately Managed Account Fees: Clients participating in separately managed account programs may be charged various program fees in addition to the advisory fee charged by our firm. Such fees may include the investment advisory fees of the advisers, which may be charged as part of a wrap fee arrangement. Additional Fees, Expenses and Taxes: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians, bankers, fund accountants, auditors and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transaction for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Advisory fees charged by our firm are subject to local and national taxes assessed in India. Taxes are calculated and listed on our billing invoice which is provided to you at the time fees are deducted from your account. Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to Avendus Wealth Management Private Limited's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum account requirements will differ among clients. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. Item 6 Performance-Based Fees and Side-By-Side Management As we disclosed in Item 5 of this Brochure, our firm charges a performance-based fee from the client. We endeavor at all times to put the interest of our clients first as part of our fiduciary duty as a registered investment adviser; accordingly, we take the following steps to address these conflicts: 1. We disclose to clients the existence of all material conflicts of interest. We collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance; 2. We conduct regular reviews of each client account to verify that all recommendations made to a client are suitable to that client's needs and circumstances; 3. We have implemented policies and procedures for fair and consistent allocation of investment opportunities among all client accounts; 4. We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients and equitable treatment of all clients, regardless of the fee arrangement. 9 The client must understand the performance-based fee method of compensation and its risks prior to entering into a management contract with us. PERFORMANCE-BASED FEES WILL ONLY BE CHARGED IN ACCORDANCE WITH THE PROVISIONS OF RULE 205-3 OF THE INVESTMENT ADVISERS ACT OF 1940 AND/OR APPLICABLE STATE REGULATIONS. THE FEES WILL NOT BE OFFERED TO ANY CLIENT RESIDING IN A STATE IN WHICH SUCH FEES ARE PROHIBITED. Item 7 Types of Clients Avendus Wealth Management Private Limited provides advisory services to the following types of clients: • Individuals (other than high net worth individuals) • High net worth individuals • Companies • Charitable organizations/Family Trust • Hindu Undivided Family • Partnership/Limited Liability Partnership Firms As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature of the service(s) being provided. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We may use one or more of the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Quantitative Analysis: We use mathematical models in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of share price or earnings per share, and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement, and predict changes to share price based on that data. A risk is using qualitative analysis is that our subjective judgment may prove incorrect. Industry Analysis: We study the state of the industries and look for good companies in that domain. 10 Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategies Depending on the client’s profile, we use one of the following investment strategies when managing client assets and/or providing investment advice: Ultra Conservative: Investment strategy is designed to preserve capital. The allocations are made to defensive assets through fixed income instruments. Investor is tolerant to debt market linked volatility. The risk of losing principal is very low for this profile. Conservative: Investment strategy is designed to mainly preserve capital. Hence only a small portion can be allocated to less volatile, Equity oriented growth assets, with majority of the allocations made to defensive assets through fixed income instruments. Investor is tolerant to debt market linked volatility. The risk of losing principal is low for this profile. Moderate: Investment strategy is to have some capital appreciation and stable income generation by investing in both fixed income & equity assets, however, share to fixed income assets will be higher. Investor is tolerant to price volatility linked to equity & debt markets and is willing to bear short to medium term losses. There can be minor allocations to Alternate assets with longer time horizon & higher volatility. There is risk of partial loss in principal in certain market conditions. Balanced: Investment strategy is designed to have a balance between debt for income generation & equity for growth of capital. Investor is tolerant to price volatility linked to equity & debt markets and is willing to bear short to medium term losses to achieve capital growth over the medium to long term. Investment mix can comprise allocations to alternate assets along with fixed income & equity assets. There is risk of sizable loss to principal in adverse market conditions.. Growth : Investment strategy is designed to focus on wealth accumulation over time through price appreciation, rather than income generation. Investor is willing to have price volatility risk associated with higher equity exposure in order to achieve higher growth. Investment mix will constitute a greater share of growth assets & alternate assets which have potential to provide capital appreciation over a long-time horizon. The risk of losing principal is significantly high, with only a small portion allocated to fixed income. 11 Aggressive: Investment strategy is to achieve above average growth over time with little focus on income generation. Investor is willing to accept higher levels of risk. There can be wide variance in results from one year to the other in pursuit of longer-term goals. Fluctuation in capital is for the greater potential of wealth accumulation. With the exception of a minimal level of cash/debt for liquidity purposes, investment mix will mainly consist of growth assets. The risk of losing principal is highest in this profile. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through our investment management program, as described below: • Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed- income investors receive set, regular payments that face the same inflation risk. • ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our 12 investment strategies do not produce the expected returns, the value of the investment will decrease. For more information on risks associated with the services, please refer to the Risk Factors given in the Disclosure Document on Portfolio Management Services available at : https://www.avendus.com/india/regulatory-information?slug=avendus-wealth-management-private- limited Item 9 Disciplinary Information There are no legal or disciplinary events against your advisory firm or a management person that are material to a client’s or prospective client’s evaluation of our business or integrity. For information on regulatory actions you may refer to the ADV which is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. Item 10 Other Financial Industry Item Activities and Affiliations Other Financial Industry Activities There are no other services provided by the firm except as detailed in Items 4 and 5 of this brochure. Affiliated Companies Avendus Wealth Management conducts activities and/or has material arrangements with some affiliates who are “related persons” as defined on the U.S. Securities and Exchange Commission’s Form ADV instructions. These activities may be material to our investment advisory business or our advisory clients. These affiliates include companies under common control of Avendus Capital Private Limited by virtue of their status as subsidiaries of Avendus Capital Private Limited. Avendus PE Investment Advisors Private Limited, Avendus Capital, Inc., Avendus Finance Private Limited, Avendus Capital Alternate Strategies Private Limited, Avendus Capital Public Markets Alternate Strategies LLP, Avendus Capital Asset Management (UK) Limited, Avendus Investment Managers Private Limited (Formerly known as Ocean Dial Asset Management India Private Limited), Avendus Capital Pte Ltd, Avendus Pte Ltd and Spark Institutional Equities Private Limited are subsidiaries of Avendus Capital Private Limited. Avezo Advisors Private Limited is an associate of the company and acts as an investment manager to funds. Avendus Capital Private Limited Our parent company is an investment banking firm providing services in the areas of Issue Management, Mergers & Acquisitions and Private Equity syndication. Our services are considered separate and independent from the investment banking services offered by our parent company. We have established procedures designed to insulate our investment management and investment recommendation services from the services of Avendus Capital Private Limited in an effort to reduce conflicts of interest that may arise between our separate lines of business. Avendus PE Investment Advisors Private Limited Avendus PE Investment Advisors Private Limited (Avendus PE) is a private limited company 13 incorporated in India and acting as Investment Manager and Co-Sponsor along with Avendus Capital Private Limited to pooled investment vehicle known as alternative investments funds registered under Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012. Further, Avendus PE has also been registered with SEBI as a Co-Investment Portfolio Manager under the SEBI (Portfolio Managers) Regulations, 2020. Due to our affiliation with Avendus PE, we have a material financial interest when recommending strategies offered through their firm, since Avendus PE is compensated for managing and operating its investment management strategies. We address for this conflict by comparing strategies offered by Avendus PE against other similar investment options and strategies available and we will recommend other investment options when more appropriate for the client. However, the following conflict of interest disclosures are provided specific to Avendus PE. Because of our affiliation with Avendus PE, we may be more reluctant or slower to move your money out of their strategies than we will be for your investments in other securities not managed by our affiliate even to the extent the strategies have poor performance. Avendus PE receives investment management fees and performance fee, as per its offering documents. Further, we receive fees for recommending our clients investment in the strategies offered and managed by Avendus PE. Unlike our Portfolio Management Services, their strategies are not managed based on your individual needs and unique investment circumstances. Instead, we will recommend the strategies if they would be suitable based on your investment circumstances. Avendus Capital Inc. Avendus Capital Inc. is a United States based broker/dealer registered with FINRA and an investment adviser with state securities Boards of New York. Avendus Capital Inc. was initially established to provide investment services in the US including Mergers & Acquisitions services and Private Equity Syndication. Avendus Finance Private Limited Avendus Finance Private Limited (AFPL) is a 100% wholly owned subsidiary of Avendus Capital Private Limited. AFPL is registered as a Non-Banking Financial Company (“Non-Deposit Taking Company”) with the Reserve Bank of India. AFPL provide loans, advances, buying and selling of fixed income securities. AFPL is also registered as a Depositary Participant. The services of AFPL and our services are considered separate and independent from the services of AFPL. However, in the capacity of being an Affiliate, AFPL may be engaged with Avendus Wealth Management Private Limited to provide aforesaid services to its clients. Avendus Capital Pte. Ltd. Avendus Capital Private Limited has established Avendus Capital Pte. Ltd as wholly owned subsidiary in Singapore. Avendus Capital Pte Ltd. carries out Fund management activities and it is registered with MAS as AI/LFMC (Capital Market Service Licence). Avendus Capital Pte Ltd has obtained the license to provide fund management services to the Master Fund and various other funds (including feeder funds/intermediate vehicles). It is also engaged in the provision of External Asset Management services to its clients. 14 Due to our affiliation with Avendus Capital Pte. Ltd, we have a material financial interest when recommending strategies offered through their firm, since Avendus Capital Pte. Ltd is compensated for managing and operating its investment management strategies. We address for this conflict by comparing strategies offered by Avendus Capital Pte. Ltd against other similar investment options and strategies available and we will recommend other investment options when more appropriate for the client. However, the following conflict of interest disclosures are provided specific to Avendus Capital Pte. Ltd. Because of our affiliation with Avendus Capital Pte. Ltd, we may be more reluctant or slower to move your money out of their strategies than we will be for your investments in other securities not managed by our affiliate even to the extent the strategies have poor performance. Avendus Capital Pte. Ltd receives investment management fees and performance fee, as per its offering documents. Further, we receive fees for recommending our clients investment in the strategies offered and managed by Avendus Capital Pte. Ltd. Unlike our Portfolio Management Services, their strategies are not managed based on your individual needs and unique investment circumstances. Instead, we will recommend the strategies if they would be suitable based on your investment circumstance. Avezo Advisors Private Limited in Avezo Advisors Private Limited is a private limited company incorporated India and acting as Investment Manager and Co-sponsor alongwith Avendus Capital Private Limited to pooled investment vehicle known as alternative investments funds registered under Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 Due to our affiliation with Avezo Advisors Private Limited we have a material financial interest when recommending strategies offered through their firm. This is because Avezo Advisors Private Limited is compensated for managing and operating its investment management strategies. We address for this conflict by comparing strategies offered by Avezo Advisors Private Limited against other similar investment options and strategies available and we will recommend other investment options when more appropriate for the client. However, the following conflict of interest disclosures are provided specific to Avezo Advisors Private Limited. Because of our affiliation with Avezo Advisors Private Limited, we may be more reluctant or slower to move your money out of their strategies than we will be for your investments in other securities not managed by our affiliate even to the extent the strategies have poor performance. Avezo Advisors Private Limited receive investment management fees and performance fee as agreed in its offering document. Further, we receive fees for recommending our clients investment in the strategies offered through Avezo Advisors Private Limited. Unlike our Portfolio Management Services, their strategies are not managed based on your individual needs and unique investment circumstances. Instead, we will recommend the strategies if they would be suitable based on your investment circumstances. Avendus Capital Public Markets Alternate Strategies LLP 15 alternative to pooled investment funds registered liability partnership registered Avendus Capital Public Markets Alternate Strategies LLP is a limited under Limited Liability Partnership Act,2008, acting as Investment Manager and Co-sponsor alongwith investment vehicle known as alternative Avendus Capital Private Limited Securities and under the investments funds Exchange Board of India (Alternative Investment Funds) Regulations, 2012 Avendus Capital PublicMarkets Alternative Strategies LLP is a US Exempt Reporting Advisor exempte d from registration since it only advises private funds and no natural individuals, and it has no location in the US. Due to our affiliation with Avendus Capital Public Markets Alternate Strategies LLP, we have a material financial interest when recommending strategies offered through their firm. This is because Avendus Capital Public Markets Alternate Strategies LLP is compensated for managing and operating its investment management strategies. We address for this conflict by comparing strategies offered by Avendus Capital Public Markets Alternate Strategies LLP against other similar investment options and strategies available and we will recommend other investment options when more appropriate for the client. However, the following conflict of interest disclosures are provided specific to Avendus Capital Public Markets Alternate Strategies LLP. Because of our affiliation with Avendus Capital Public Markets Alternate Strategies LLP, we may be more reluctant or slower to move your money out of their strategies than we will be for your investments in other securities not managed by our affiliate even to the extent the strategies have poor performance. Avendus Capital Public Markets Alternate Strategies LLP receives investment management fee and performance fee, as stated and agreed in its offering document. Further, we receive fees for recommending our clients investment in the strategies offered through Avendus Capital Public Markets Alternate Strategies LLP. Unlike our Portfolio Management Services, their strategies are not managed based on your individual needs and unique investment circumstances. Instead, we will recommend the strategies if they would be suitable based on your investment circumstances. Avendus Capital Alternate Strategies Private Limited Avendus Capital Alternate Strategies Private Limited is a Company registered under Companies Act, 2013. The main object of the Company is to act as manager, consultants, advisors, portfolio manager, administrators, attorneys, agents, or representative of domestic and offshore venture capital funds, private equity funds, offshore funds, provident funds, insurance funds or any other funds formed or established in India or elsewhere by the Company. As on date, the Company is not carrying any business activity. 16 is an entity registered at the UK and is a Special the on date Avendus Capital Asset Management (UK) Limited (UK) Limited Avendus Capital Asset Management Purpose Vehicle, Wholly Owned Subsidiary of Avendus Capital Private Limited. As Company holds shares of Asset Co Plc. Avendus Investment Managers Private Limited (Formerly known as Ocean Dial Asset Management India Private Limited) Avendus Investment Managers Private Limited (Formerly known as Ocean Dial Asset Management India Private Limited) is a private limited company incorporated in India and acting as Investment Manager and Co-sponsor along with Avendus Capital Private Limited to pooled investment vehicle known as alternative investments funds registered under Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012. It also registered as Portfolio Manager under the SEBI (Portfolio Managers) Regulations, 2020 providing discretionary portfolio management services and advisory services . Due to our affiliation with Avendus Investment Managers Private Limited , we have a material financial interest when recommending strategies offered through their firm, since Avendus Investment Managers Private Limited is compensated for managing and operating its investment management strategies. We address for this conflict by comparing strategies offered by Avendus Investment Managers Private Limited against other similar investment options and strategies available and we will recommend other investment options when more appropriate for the client. However, the following conflict of interest disclosures are provided specific to Avendus Investment Managers Private Limited Because of our affiliation with Avendus Investment Managers Private Limited , we may be more reluctant or slower to move your money out of their strategies than we will be for your investments in other securities not managed by our affiliate even to the extent the strategies have poor performance. Avendus Investment Managers Private Limited receives investment management fees and performance fee, as per its offering documents. Further, we receive fees for recommending our clients investment in the strategies offered and managed by Avendus Investment Managers Private Limited . Unlike our Portfolio Management Services, their strategies are not managed based on your individual needs and unique investment circumstances. Instead, we will recommend the strategies if they would be suitable based on your investment circumstance. Spark Institutional Equities Private Limited (“Spark”) Spark Institutional Equities Private Limited is a SEBI registered Stock Broker and Research Analyst offering broking and research services to domestic and offshore institutions, Banks, corporates, and HNI clients. The entity is a subsidiary of Avendus Capital Private Limited. Avendus Wealth Management carries out its wealth management activities independently. Avendus Pte. Ltd. Avendus Pte. Ltd. is licensed with Monetary Authority of Singapore for a capital markets services [“CMS”] license to conduct the regulated activities of advising on corporate finance and dealing in capital 17 markets products that are securities and exchange-traded derivatives contracts. Other Financial Industry Affiliates As explained in Item 4 of this brochure, Redpoint Investments Pte Ltd holds 62.76% in the total paid up share capital of the parent company i.e. Avendus Capital Private Limited. Funding to Redpoint has been provided by funds managed by KKR Asian Fund II LP (KKR) and/or its affiliates. We may distribute funds managed by KKR entities and receive commissions for the same from KKR entities, subject to applicable regulations. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Securities Transactions Our firm has adopted policies and procedures, which set forth high ethical standards of business, conduct that we require of our employees, including compliance with applicable federal securities laws. Avendus Wealth Management Private Limited and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the policies and procedures but to the general principles that guide the Policies. Our policies and procedures include collection of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our policies also require the prior approval for dealing in listed securities. Our code also provides for oversight, enforcement and recordkeeping provisions. Avendus Wealth Management Private Limited's policies and procedures further include the firm's policy prohibiting the misuse of material non-public information. Avendus Wealth Management Private Limited may, at times, effect an agency cross transaction for an advisory client, provided that the transaction is consistent with our firm's fiduciary duty to the client and that all requirements outlined in Sec. 206(3)-2 of the Investment Advisers Act of 1940 are met. This section is intended to provide a summary description of the Code of Ethics of Avendus Wealth Management. If you wish to review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your request, we will promptly provide a copy of the Code of Ethics to you. Agency Cross Transactions An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory clients and for another person on the other side of the transaction. Agency cross transactions typically may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Agency cross transactions are permitted for advisers only if certain conditions are met under Section 206(3) of the Investment Advisers Act of 1940 or SEC Rule 206(3)-2. As a fiduciary, the interests of our clients must always be placed first. The trading policies and procedures of Avendus Wealth Management prohibit unfair trading practices and seek to avoid conflicts of interests, where possible, or to disclose conflicts when they arise. We will attempt to resolve conflicts in the client’s favor when reasonably possible. We may engage in an agency cross transaction only when it is deemed to be in the best interests of both clients and neither client is disfavored. Such cross transactions will only be used when it can be determined that doing so would achieve “best execution” and benefit the clients involved by saving 18 commissions, market impact costs, and other transaction charges. Agency cross transactions involving an advisory client will be transacted without any compensation, unless specifically approved by our Chief Compliance Officer in compliance with the above criteria and in accordance with either Section 206(3) of the Investment Advisers Act of 1940 or SEC Rule 206(3)-2. Where compensation is approved for an agency cross transaction involving advisory clients, we will provide a written disclosure to the customers that we will act as broker for, receive compensation from, and have a potential conflicting division of loyalties regarding both parties to the transaction. We will also receive written, executed consent from the client prospectively authorizing us to effect agency cross transaction in client’s accounts. Where compensation is charged, we will send to each client at or before completion of the transaction, information, which includes the date of the transaction, a statement of the nature of the transaction, an offer to furnish the time the transaction took place, and the total of all compensation received. We will provide each client, who was a party to an agency cross transaction for compensation, an annual written disclosure statement identifying the total number of agency cross transactions since the last statement, and the total compensation received. Item 12 Brokerage Practices When purchasing equity securities on your behalf, going forward you will need to open a broking account with Emkay Global Financial Services Ltd. (referred to as “Emkay”), an introducing broker/dealer, and then settled through HDFC Bank Limited an India registered Custodian that services as qualified Custodian of all securities. Axis Bank Limited (referred to as "Axis") is an additional Custodian for Portfolio Management Services. Emkay/Axis/HDFC is not affiliated with Avendus Wealth Management. In addition to serving as the clearing broker/dealer, Axis/ HDFC serves as the qualified Custodian for portfolio management accounts. HDFC Bank serves as the qualified Custodian to hold client funds and cash balances. The decision to require the use of Emkay is based on Avendus Wealth Management’s decision that Avendus Wealth Management can provide efficient and cost-effective services through Emkay. The requirement to use Axis/ HDFC (which is not affiliated with Avendus Wealth Management) is based on the fact that a settlement arrangement with Axis/ HDFC which are qualified Custodian for equity securities has been established. There are some investment advisors that permit the use of multiple broker/dealers and permit clients to select the broker/dealer. Avendus Wealth Management has considered the positive factors to this approach which include the ability to better negotiate brokerage costs such as transaction fees, the ability to better analyze speed of execution, and the ability to compare and negotiate services. Considering all factors in relation to Avendus Wealth Management’s structure and capacities, Avendus Wealth Management has concluded that one brokerage arrangement suggested by Avendus Wealth Management (i.e. Emkay) is a better policy than utilizing multiple brokerage platforms. However, the clients are free to choose their broker. However, the current policy may change in the future and if Avendus Wealth Management decides to change brokerage arrangements all clients will be made aware of the change in policy. Avendus Wealth Management may review commission and fee structures of various broker/dealers, along with services, research and tools in order to evaluate the overall execution services provided by Emkay and Axis/ HDFC against the other broker/dealers. Accordingly, while Avendus Wealth Management will consider competitive rates, it may not necessarily obtain the lowest possible 19 commission and brokerage rates for client account transactions. Therefore, the overall services provided by Emkay and Axis/ HDFC are evaluated to determine the level of best execution provided to clients. However, considering Avendus Wealth Management requires its clients to use the brokerage services of Emkay and Axis/ HDFC, Avendus Wealth Management may not be able to achieve the most favorable execution of client transactions and therefore Avendus Wealth Management’s practice of requiring the use of Emkay and Axis/ HDFC may cost clients more money compared to advisory programs offered by other investment advisors. While clients may be able to attain brokerage services with lower costs and expenses, clients should be aware of some of the qualitative factors Avendus Wealth Management considers for selecting Emkay/ Axis/ HDFC. These factors include, but are not necessarily limited to, being able to rely on the internal staff of Emkay to provide operations, trading, and other services. Further, associates and other departments of the Avendus Wealth Management may receive fees from the third parties in connection with investment of fund of clients in the products of third parties Item 13 Review of Accounts REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are monitored, these accounts are reviewed periodically. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by Avendus Wealth Management Private Limited team. REPORTS: In addition to the statements and confirmations of transactions that clients receive from their broker-dealer as agreed, we provide quarterly reports summarizing account performance, balances and holdings. Item 14 Client Referrals and Other Compensation CLIENT REFERRALS Our firm may pay referral fees to independent persons or firms ("Solicitors") for introducing clients to us. Whenever we pay a referral fee, we require the Solicitor to provide the prospective client with a copy of this document (our Firm Brochure) and a separate disclosure statement that includes the following information according to the Cash Solicitation Rule of the Advisers Act of 1940: • the Solicitor's name and relationship with our firm; • the fact that the Solicitor is being paid a referral fee; • the amount of the fee; and • Whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Solicitor. As a matter of firm practice, the advisory fees paid to us by clients referred by solicitors are not increased as a result of any referral. Item 15 Custody Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment adviser has the ability to access or control client funds or securities, the investment adviser is deemed to have custody and must ensure proper procedures are implemented. 20 Avendus Wealth Management is deemed to have custody of client funds and securities whenever Avendus Wealth Management is given the authority to have fees deducted directly from client accounts. However, this is the only form of custody Avendus Wealth Management will ever maintain. It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. For accounts in which Avendus Wealth Management is deemed to have custody, we have established procedures to ensure: (1) All client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. (2) Clients open the accounts directly with the custodian and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. (3) Finally, account statements are delivered by Avendus Wealth Management to each client, or the client’s independent representative, at least quarterly. Clients should carefully review reports and statements received from Avendus Wealth Management. When clients have questions about their account statements, they should contact Avendus Wealth Management. Item 16 Investment Discretion When providing portfolio management services, Avendus Wealth Management maintains trading authorization over your Account and can provide management services on a discretionary basis. When discretionary authority is granted, we will have the authority to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you prior to implementing changes in your account. Therefore, you will be contacted and required to accept or reject our investment recommendations including: • The security being recommended • The number of shares or units • Whether to buy or sell • The price of the security Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment. If your accounts are managed on a non-discretionary basis, you need to know that if we are not able to reach you or you are slow to respond to our request, it can have an adverse impact on the timing of trade implementations, and we may not achieve the optimal trading price. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to Avendus Wealth Management so long as the limitations are specifically set forth or included as an attachment to the client agreement. Item 17 Voting Client Securities Avendus Wealth Management does not vote proxies on behalf of Clients. Therefore, it is your responsibility to vote all proxies for securities held in your accounts. 21 Item 18 Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. As an advisory firm that maintains discretionary authority for client accounts, we are also required to disclose any financial condition that is reasonable likely to impair our ability to meet our contractual obligations. Avendus Wealth Management Private Limited has not been the subject of a bankruptcy petition at any time since inception. 22 Customer Privacy Policy Notice Our Commitment to You Avendus Wealth Management (“Avendus”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Avendus (also referred to as "we", "our" and "us" throughout this notice) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust. Avendus does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and proper business purposes in connection with the servicing and management of our relationship with you as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Privacy Policy. Why you need to know? Registered Investment Advisors (“RIAs”) share some of your personal information. Federal and State laws give you the right to limit some of this sharing. Federal and State laws require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities / Net-worth Name, address and phone number(s) Income and expenses E-mail address(es) Account information (including other institutions) Investment activity KYC Documents as mandated by regulations and Investment experience and goals What sources do we collect information from in addition to you? Custody, brokerage and advisory agreements questionnaires and suitability Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment documents Other information needed to service account How we share your information? RIAs do need to share personal information regarding its clients to effectively implement the RIA’s services. In the section below, we list some reasons we may share your personal information. 23 Sharing Limitations Basis for sharing Servicing our Clients We may share non-public personal information with our affiliates and group companies and non-affiliated third parties (such as brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed services to you consistent with applicable law, including but not limited to: Avendus may share this information. Clients cannot limit the Advisors ability to share. • Processing transactions; • General account maintenance; • Responding to regulators or legal investigations; and • Credit reporting, etc. Avendus may share this information. Clients cannot limit the Advisors ability to share. Avendus does not share personal information. Clients cannot limit the Advisors ability to share. Administrators We may disclose your non-public personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested. Marketing Purposes Avendus does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Avendus or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Avendus does share personal information. Clients can limit the Advisors ability to share. Authorized Users In addition, your non-public personal information may also be disclosed to you and persons we believe to be your authorized agent or representative. information Clients can limit the Advisors ability to share. Information About Former Clients Avendus does not disclose, and does not intend to disclose, non-public personal to non- affiliated third parties with respect to persons who are no longer our clients. Avendus does not share personal information regarding former clients How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and electronic safeguards. These include computer safeguards such as passwords, secured files and buildings. 24 Our employees are advised about Avendus's need to respect the confidentiality of each client’s non- public personal information. We train our employees on their responsibilities. We require third parties that assist in providing our services to you to protect the personal information they receive. This includes contractual language in our third-party agreements. Changes to our Privacy Policy. We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our Privacy Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Questions/ Grievances/Complaints: • You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (91-22) 66481295 or via email at palak.furia@avendus.com • For any complaints/grievances you can write to us on awmplig@avendus.com. • For other operational queries you can write to us on AWMcare@avendus.com. 25 Form ADV Part 2B – Brochure Supplement For Apurva Sahijwani Managing Director & Chief Executive Officer Effective June 28, 2025 This Brochure Supplement provides information about the background and qualifications of Apurva Sahijwani (CRD #7949699) in addition to the information contained in the Avendus Wealth Management Private Limited (“Avendus” or the “Advisor” - Disclosure Brochure). If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Avendus Disclosure Brochure or this Brochure Supplement, please contact us at +91-22-66480909 by email at palak.furia@avendus.com Additional information about Mr. Sahijwani is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 26 Item 2: Educational Background and Business Experience Apurva Sahijwani , Chief Executive Officer & Managing Director Year of Birth: 1976 Education: • Master of Business Administration (MBA) from Gujarat University (May-1998) • Bachelor of Business Administration (BBA) from Gujarat University (May-1996) • Diploma in Business Finance (DBF) from ICFAI (Jun-1998) Business Background: Managing Director & Chief Executive Officer , Avendus Wealth Management Private Limited, since May 2024 25 years+ of extensive experience in private banking and wealth management, Apurva spearheads the seasoned wealth team and leverages the entire Avendus platform to advise clients holistically. Prior to joining Avendus, he spearheaded Burgundy Private, Axis bank's private banking arm. He has also held several key management positions at Kotak Wealth, ICICI Bank, HSBC, Citibank. Item 3: Disciplinary Information Mr. Sahijwani does not have any history of disciplinary events. Item 4: Other Business Activities Mr. Sahijwani does not have any other business activities to report. Item 5: Additional Compensation Mr. Sahijwani does not receive any other additional compensation. Item 6: Supervision Apurva is the Chief Executive Officer & Managing Director- Avendus Wealth Management Private Limited and joined Avendus Wealth Management Private Limited in May 2024.He has extensive experience in wealth management as an industry. 27 Form ADV Part 2B – Brochure Supplement For Palak Furia Chief Compliance Officer Effective June 28, 2025 This Brochure Supplement provides information about the background and qualifications Palak Furia (CRD # 7949694) in addition to the information contained in the Avendus Wealth Management Private Limited (“Avendus” or the “Advisor” - Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Avendus Disclosure Brochure or this Brochure Supplement, please contact us at +91-22-66480909 by email at palak.furia@avendus.com Additional information about M s . F u r i a is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 28 Item 2: Educational Background and Business Experience Palak Furia, Chief Compliance Officer Year of Birth: 1988 Education: Ms. Furia is a qualified Chartered Accountant Business Background: Item 3: Disciplinary Information Ms. Furia does not have any history of disciplinary events. Item 4: Other Business Activities Ms. Furia does not have any other business activities to report. Item 5: Additional Compensation Ms. Furia does not receive any other additional compensation. Item 6: Supervision Ms. Furia is Chief Compliance Officer at Avendus Wealth Management. She reports to Head- Compliance of Avendus Wealth Management Private Limited. These employees can be reached by calling 912266480909 29 Form ADV Part 2B – Brochure Supplement For Saurabh Rungta Chief Investment Officer Principal Officer – Portfolio Management Service Effective June 28, 2025 This Brochure Supplement provides information about the background and qualifications Saurabh Rungta (CRD#7949685) n addition to the information contained in the Avendus Wealth Management Private Limited (“Avendus” or the “Advisor” - Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Avendus Disclosure Brochure or this Brochure Supplement, please contact us at +91-22-66480909 by email at palak.furia@avendus.com Additional information about Mr. Rungta is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 30 Item 2: Educational Background and Business Experience Saurabh Rungta, Chief Investment Officer Year of Birth: 1982 Education: C h a r t e r e d A c c o u n t a n t Business Background: Senior managing partner and Chief Investment Officer – Nuvama Wealth Management Limited – October 2018 to November 2023 Head of Products – Kotak Wealth Management – June 2012 to September 2018 Head of International Products -= IIFL Wealth Management – Feb 2010 to May 2012. Prior to the above, Mr. Rungta has also worked with ICICI group and Citi group. Item 3: Disciplinary Information Mr. Rungta does not have any history of disciplinary events. Item 4: Other Business Activities Mr. Rungta does not have any other business activities to report. Item 5: Additional Compensation Mr. Rungta does not receive any other additional compensation. Item 6: Supervision Mr. Rungta is part of the senior management team at Avendus Wealth and is responsible for the firm's product and advisory capabilities in equity, fixed income, alternate and real estate asset classes etc. Avendus Wealth Management Private Limited also employs Ms. Palak Furia as Chief Compliance Officer who, is responsible for maintaining a compliance program and compliance oversight for all employees. Ms. Furia also reviews Mr. Rungta’s personal securities transactions for any irregularities. These employees can be reached by calling 912266480909 31 Form ADV Part 2B – Brochure Supplement For Zarksis Gotla Executive Director Effective June 28, 2025 This Brochure Supplement provides information about the background and qualifications Mr. Zarksis Gotla in addition to the information contained in the Avendus Wealth Management Private Limited (“Avendus” or the “Advisor” - Disclosure Brochure). If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Avendus Disclosure Brochure or this Brochure Supplement, please contact us at +91-22-66480909 by email at palak.furia@avendus.com Additional information about Mr. Gotla is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 32 Item 2: Educational Background and Business Experience Mr. Zarksis Gotla, Executive Director, Client Relations Year of Birth: 1969 Education: Chartered Accountant Business Background: Mr. Gotla is associated with Avendus Wealth Management in client relations since September, 2010. Prior to joining Avendus Wealth Management, Mr. Gotla has worked with Deutsche Bank as Director - Client Relations from 2005 to 2010. He has worked as Vice President – Private Banking in BNP Paribas from 1997 to 2004. Mr. Gotla has an overall work experience of 28 years. Item 3: Disciplinary Information Mr. Gotla does not have any history of disciplinary events. Item 4: Other Business Activities Mr. Gotla does not have any other business activities to report. Item 5: Additional Compensation Mr. Gotla does not receive any other additional compensation. Item 6: Supervision Mr. Gotla , Executive Director - Client Relations, is part of the Client Relations team. He reports to Mr. Apurva Sahijwani, Managing Director and CEO. Avendus Wealth Management Private Limited also employs Ms. Palak Furia as Chief Compliance Officer who, is responsible for maintaining a compliance program and compliance oversight for all employees. Ms. Furia also reviews Mr. Gotla’s personal securities transactions for any irregularities. These employees can be reached by calling 912266480909 33 Form ADV Part 2B – Brochure Supplement For Manoj Vaswani Executive Director Effective June 28, 2025 This Brochure Supplement provides information about the background and qualifications Mr. Manoj Vaswani in addition to the information contained in the Avendus Wealth Management Private Limited (“Avendus” or the “Advisor” - Disclosure Brochure). If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Avendus Disclosure Brochure or this Brochure Supplement, please contact us at +91-22- 66480909 by email at palak.furia@avendus.com Additional information about Mr. Vaswani is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 34 Item 2: Educational Background and Business Experience Manoj Vaswani, Executive Director Year of Birth: 1982 Education: MBA (PGDM) – IIM Calcutta (2004-2006) Bachelor of Commerce – Loyola College, Chennai (1999-2002) Business Background: Mr. Vaswani is associated with Avendus Wealth Management in client relations since October 2014. Prior to joining Avendus, Mr. Vaswani has worked with Kotak Mahindra Bank – Wealth Management in client relations from June 2006 to October 2014. and with e-Serve International Ltd. From July 2002 – May 2004 (Personal Loan Processing). Mr. Vaswani has an overall experience of 18 years. Item 3: Disciplinary Information Mr. Vaswani does not have any history of disciplinary events. Item 4: Other Business Activities Mr. Vaswani does not have any other business activities to report. Item 5: Additional Compensation Mr. Vaswani does not receive any other additional compensation. Item 6: Supervision Mr. Vaswani is a part of the Client Relations team at Avendus Wealth in Bangalore. He reports to Mr. Apurva Sahijwani, Managing Director and CEO. Avendus Wealth Management Private Limited also employs Ms. Palak Furia as Chief Compliance Officer who, is responsible for maintaining a compliance program and compliance oversight for all employees. Ms. Furia also reviews Mr. Vaswani’s personal securities transactions for any irregularities. These employees can be reached by calling 912266480909 35 Form ADV Part 2B – Brochure Supplement For Rajeev Mundhada Vice President Effective June 28, 2025 This Brochure Supplement provides information about the background and qualifications Mr. Rajeev Mundhada in addition to the information contained in the Avendus Wealth Management Private Limited (“Avendus” or the “Advisor” - Disclosure Brochure). If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Avendus Disclosure Brochure or this Brochure Supplement, please contact us at +91-22-66480909 by email at palak.furia@avendus.com. Additional information about Mr. Mundhada is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 36 Item 2: Educational Background and Business Experience Rajeev Mundhada, , Vice President Year of Birth: 1987 Education: B. Tech (Production Engineering) – Veermata Jijabai Technological Institute MBA (Investment Banking & Wealth Management) – S P Jain School of Global Management Business Background: Mr. Mundhada has an overall experience of 11 Years in Financial services. Prior to joining Avendus Wealth Management, he has worked with 360 One WAM Limited for 8.5 years handling client relations Item 3: Disciplinary Information Mr. Mundhada does not have any history of disciplinary events. Item 4: Other Business Activities Mr. Mundhada does not have any other business activities to report. Item 5: Additional Compensation Mr. Mundhada does not receive any other additional compensation. Item 6: Supervision Mr. Mundhada is Vice President, part of the client relations team at Avendus Wealth Management. He works closely with the Mr. Pravin Somani - Executive Director, in growing the Wealth Management franchise at Avendus Wealth Management. He reports to Mr. Somani. . Avendus Wealth Management Private Limited also employs Ms. Palak Furia as Chief Compliance Officer who, is responsible for maintaining a compliance program and compliance oversight for all employees. Ms. Furia also reviews Mr. Mundhada’s personal securities transactions for any irregularities. These employees can be reached by calling 912266480909 37 Form ADV Part 2B – Brochure Supplement For Mohan Rahul Tulluri Executive Director Effective June 28, 2025 this Brochure Supplement, please contact us at +91-22-66480909 This Brochure Supplement provides information about the background and qualifications Mr. Mohan Rahul Tulluri in addition to the information contained in the Avendus Wealth Management Private Limited (“Avendus” or the “Advisor” - Disclosure Brochure). If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Avendus Disclosure Brochure by email at or palak.furia@avendus.com. Additional information about Mr. Tulluri is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 38 Item 2: Educational Background and Business Experience Mohan Rahul Tulluri, Executive Director Year of Birth: 1986 Education: Bachelor of Business Administration from ICFAI National College Business Background: Mr. Tulluri overall experience of 17+years in Financial services across corporate banking & wealth management. Started his career with Birla sunlife Insurance & Prior to joining Avendus Wealth Management, he has worked with Citbank as Vice President and was responsible for managing Citigold clients. Item 3: Disciplinary Information Mr. Tulluri does not have any history of disciplinary events. Item 4: Other Business Activities Mr. Tulluri does not have any other business activities to report. Item 5: Additional Compensation Mr. Tulluri does not receive any other additional compensation. Item 6: Supervision Mr. Tulluri is Executive Director, part of the client relations team at Avendus Wealth Management. He works closely with the Mr. Anubhaw Chandak Managing Director, in growing the Wealth Management franchise at Avendus Wealth Management. Avendus Wealth Management Private Limited also employs Ms. Palak Furia as Chief Compliance Officer who, is responsible for maintaining a compliance program and compliance oversight for all employees. Ms. Furia also reviews Mr. Tulluri ‘s personal securities transactions for any irregularities. These employees can be reached by calling 912266480909 39 Acknowledgement Letter for Disclosure Brochure, Privacy Notice & Agreement. Date: Dear As registered investment adviser, SEC rules under the investment Advisers Act (or applicable state regulations) require that a written disclosure be delivered to each client and prospective client and that the firm maintain certain records as to the delivery of the Firm’s ADV Part II or other disclosure brochure. Our disclosure brochure describes our firm’s advisory services, investment professionals, fees and conflicts, among other things. Also, and as a client, you have provided personal and financial information as a part of our professional relationship which is personal, non-public and private. Our firm has a formal Privacy Policy to respect and protect your privacy and to safeguard and restrict access to your personal information. Federal and state regulations require our firm to initially deliver and annually send our Privacy Policy Notice to you, and a copy is enclosed. This letter will document that you have received a copy of our firm’s a) Privacy Notice, b) current Form ADV part II, or other disclosure brochure, at least 48 hours before or at the time of entering into an advisory agreement and c) investment advisory agreement. If the disclosure brochure is delivered at the time of entering into an agreement, you have the right to terminate the agreement without penalty within five business days of entering into the agreement. Kindly sign and date this acknowledgement letter below to indicate that you have received our firm’s a) Privacy Policy, b) Form ADV Part II (or other disclosure brochure) and advisory agreement. Thank you for your cooperation. Sincerely, Apurva Sahijwani Managing Director --Avendus Wealth Management Private Limited. T: +91 22 6648 0909. F: +91 22 6648 1440 CLIENT ACNOWLEDGEMENT Name: Signature: Date: 40