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 63.45% in the total paid up share capital of the Avendus Capital Private Limited. Funding to Redpoint has been provided by funds managed by KKR Group Partnership 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 16.65% 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 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:
• 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 Avendus Wealth Management. The POA could be revoked by the client at any time. For pool trading you would open the Portfolio account with Avendus Wealth Management Private Limited and the Custody account with HDFC Bank Limited. 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). 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. registered securities and investments. Therefore, we recommend you consult with other financial professionals for advice on U.S. investments. 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 3/21/2023 we were actively managing total client assets of $1,673,667,926. on a non- discretionary basis.