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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.
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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.
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Item 3: Table of Contents
Particulars
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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
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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:
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• 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).
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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.
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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.
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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
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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.
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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.
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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.
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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
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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
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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