Background

This investor grievance policy sets forth Zerodha Broking Limited’s (Zerodha)/PensionBox policy on all types of queries / complaints received and methodology for quick redressal of the same in relation to the National Pension System (NPS) and our role as a Point of Presence (PoP)/(Pension Agent/Tech Platform). The policy also lays down the responsibility and turn-around time for redressal of such queries / complaints taking into consideration the regulatory timelines and redressal mechanisms.

Definition of Complaint in terms of Regulation 2(g) of PFRDA (REDRESSAL OF SUBSCRIBER GRIEVANCE REGULATIONS) 2015

“Grievances or Complaint” includes any communication that expresses dissatisfaction, in respect of the conduct or any act of omission or commission or deficiency of service on the part of, an intermediary or an entity or a person governed by the provisions of the Act and in the nature of seeking a remedial action but do not include the following.

i. complaints that are incomplete or not specific in nature.

ii. communications in the nature of offering suggestions.

iii. communications seeking guidance or explanation.

iv. complaints which are beyond the powers and functions of the Authority or beyond the provisions of the Act and the rules and regulations framed thereunder.

v. any disputes between intermediaries and

vi. complaints that are sub-judice (cases which are under consideration by court of law or quasi-judicial body) except matters within the exclusive domain of the Authority under the provisions of the Act; Accordingly, communications received from the subscribers with regard to Clause 2 (i to vi) shall not be considered as complaints.

Scope of the Policy:

The policy aims to address the following:

a) Complaint handling procedures.

b) Acknowledgement to subscriber or Complainant.

c) Response to the subscriber and turnaround time(TAT).

Acknowledgment of Complainant:

Acknowledgment of the complaint will be given to he investor who has submitted a written query / complaint within 3 working days of the receipt of the complaint. The acknowledgement will contain the date of receipt of complaint/grievance, unique grievance number, expected date for resolution of grievance, name, designation and contact details of the Zerodha/PensionBox officer, grievance escalation matrix with contact details and address (includes organizational levels, NPS Trust and Ombudsman) and manner and mode of tracking resolution of grievance/complaint with the unique grievance number.

Response to Complainant:

On receipt of the complaint, the following steps shall be followed:

Zerodha Broking Limited/PensionBox endeavours to address and resolve all complaints received from an aggrieved investor within the regulator-prescribed turnaround timeof 30 days of filing the complaint.

a) As recorded above, the acknowledgement of the complaint shall be sent to the subscriber within a maximum period of three (3) working days and the date of sending acknowledgement to the subscriber shall be updated in Central Grievance Management System (CGMS).

b) Details of the complaints received (resolved and open), if any, shall also be placed before the Board of Directors of the Company.

c) In case the matter referred by subscriber does not pertain to PensionBox/Zerodha, Zerodha shall transfer the complaint to the relevant intermediary wihtin a period of 3 working days, on intimation to the subscriber/client.

d) If the grievance/complaint is resolved within a period of three (3) days from the date of receipt of grievance/complaint, the acknowledgement along with the resolution shall be intimated to the subscriber.

e) The unresolved grievance/ complaints/ escalations, if any, shall be handled as per the process recorded in clause 5 above.

f) The subscriber shall be intimated on resolution of grievance/complaint via email/SMS.

Closure of grievance:

In terms of Regulation 7 of PFRDA (Redressal Of Subscriber Grievance Regulations) 2015, the grievance shall be considered as disposed off and closed in any of the following instances:

a) when PensionBox/Zerodha Broking Limited has acceded to the request of the complainant fully;

b) where the complainant has indicated in writing, its acceptance of the response of PensionBox/Zerodha Broking Limited.

c) where the complainant has not responded within forty-five days of the receipt of the written response of the PensionBox/Zerodha Broking Limited.

d) where the Grievance Redressal Officer has certified under intimation to the subscriber that PensionBox/Zerodha Broking Limited has discharged its contractual, statutory and regulatory obligations and therefore closes the complaint.

e) where the complainant has not preferred any appeal within forty-five days from the date of receipt of resolution or rejection of the grievance communicated by PensionBox/Zerodha Broking Limited.

f) where the decision of the Ombudsman in appeal has been communicated to such a complainant: Provided that the closure shall not be applicable where the Ombudsman or the Authority, as the case may be, has allowed filing of the appeal, beyond the specified period.

Categorization of complaints:

In terms of Regulation 8 of PFRDA (Redressal Of Subscriber Grievance Regulations) 2015, PensionBox/Zerodha Broking Limited shall maintain categorization of the complaints as specified by the Regulator from time to time.

Submission of Reports to the Regulator:

In terms of Regulation 6(9) of PFRDA (REDRESSAL OF SUBSCRIBER GRIEVANCE REGULATIONS) 2015, PensionBox/Zerodha Broking Limited shall submit periodic reports to the National Pension System Trust or Authority as may be specified from time to time.

Maintenance of records:

a) PensionBox/Zerodha shall ensure maintenance of records of all grievances/complaints received, resolution and closure.

b) PensionBox/Zerodha shall also ensure the complaint status shall be updated as required by law and regulations.

Review of Grievance Redressal Policy:

The Policy shall be reviewed annually, or as and when any new requirement is specified by PFRDA.