Investor Grievances Redressal Policy

1. Preamble and Regulatory Basis

VVD AIF Trust (“the Fund”) is registered with the Securities and Exchange Board of India (“SEBI”) as a Category III Alternative Investment Fund under the SEBI (Alternative Investment Funds) Regulations, 2012, bearing registration number IN/AIF3/25-26/2085. VVD Asset Managers LLP (“VVD” or the “Investment Manager”) acts as the Investment Manager to the Fund and is committed to a transparent, fair and time‑bound grievance redressal mechanism for all investors of its Alternative Investment Funds (“AIFs”).

This Policy sets out the channels, timelines, escalation path and dispute‑resolution mechanisms available to investors, consistent with the Securities and Exchange Board of India (SEBI) Master Circular for AIFs and SEBI’s Online Dispute Resolution (ODR) framework.

This Policy is framed in accordance with:

SEBI Circular No. SEBI/HO/IMD/IMD-I/DOF9/P/CIR/2021/682 (December 10, 2021) – Mandatory Investor Charter, complaint disclosure requirements, and PPM updates.
SEBI SCORES Framework – Requirement for escalation of unresolved investor grievances through SEBI’s online complaints platform.
SEBI Circular No. SEBI/HO/OIAE/IGRD/CIR/P/2023/156 (September 20, 2023) – Integration of SCORES with Online Dispute Resolution (ODR).
SEBI Circular No. SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 dated July 31, 2025 – Mandatory compliance with digital accessibility requirements under the Rights of Persons with Disabilities Act, 2016, including accessibility of investor-facing grievance redressal
mechanisms.

2. Grievance Redressal Process

Step 1 — Register the complaint with Investment Manager (Primary Resolution Stage)

Investors may lodge complaints, seek clarifications, or raise service-related concerns with the Investment Manager through written communication, telephonically, or by email to the designated Service Desk. Upon receipt of a grievance, the Investment Manager shall acknowledge the complaint within 48 hours and shall make all reasonable efforts to resolve the same within 21 days from the date of receipt. This mirrors SEBI’s Investor Charter requirements and ensures an opportunity for resolution before escalation.

Step 2 — Escalation to SEBI SCORES

If the grievance remains unaddressed or unresolved beyond 21 days, or if the investor is dissatisfied with the Investment Manager’s response, the investor may escalate the complaint on SEBI’s platform – SCORES.

Complaint to be lodged within one (1) year from the cause of action.
The Investment Manager shall file an Action Taken Report (ATR) within SEBI-specified timelines.
When a complaint is closed on SCORES (by the Investment Manager or SEBI), investors have up to 15 days to request a one-time review of that closure within the platform.
At any stage, investors may also choose to pursue the ODR process or other legal remedies. If such options are exercised while the matter is still open on SCORES, the complaint will be deemed closed on SCORES.

Step 3 — Online Dispute Resolution (ODR) via SMART ODR Portal

Where a grievance remains unresolved after SCORES, or involves legal determination or third-party rights, the investor may access SEBI’s SMART ODR Portal, subject to applicable guidelines.

ODR is available only for disputes that are arbitrable and not pending before any court, tribunal, or arbitration forum.
Investors may also initiate ODR after being dissatisfied with the Investment Manager’s response, in line with SEBI guidelines.
Choosing ODR does not affect the investor’s right to pursue other legal remedies outside the platform.

b. Accessibility-Enabled Investor Grievance Redressal

The Investment Manager shall maintain an accessible, non-discriminatory grievance redressal mechanism for persons with disabilities, in compliance with the Rights of Persons with Disabilities Act, 2016 and applicable SEBI guidelines on digital accessibility.

Investors may lodge and track grievances through accessible digital channels or alternate
modes, including email, telephone, or assisted mechanisms.
Accessibility-related complaints may also be submitted to a designated Accessibility Nodal
Officer, whose contact details shall be appropriately disclosed.

3. Turnaround Times (TATs)

Complaint acknowledgement by the Investment Manager at the primary stage- within 48 hours
Complaint resolution at the Investment Manager level, unless escalation is required- within 21 days
SCORES escalation & ATR – as per SEBI timeline
- Escalation allowed if complaints are unresolved after 21 days or investor dissatisfied.
- Complaint must be lodged within 1 year of cause of action.
- ATR filing is mandatory within SEBI specified period.
- One-time review available within 15 days of closure (as per SEBI framework).
ODR initiation – Post SCORES closure/review
- Conducted via SEBI’s SMART-ODR platform, subject to eligibility and provided the matter is not pending before another forum.

4. Recordkeeping, Disclosure and Transparency

The Company shall maintain a Complaint Register capturing the date of receipt, nature of complaint, status, resolution details, and time taken for closure. All complaints, together with related correspondence (including filings on SCORES and the SMART ODR Portal), shall be documented and preserved for such period as may be prescribed by SEBI or other applicable regulatory authorities.

The Company shall also comply with SEBI-mandated disclosures, including:

Acknowledgement and Updates: Investors shall be provided with acknowledgment of complaints and periodic updates on the status until closure.
Website Disclosure: The grievance redressal process, contact details, and summary statistics of complaints shall be disclosed, in line with SEBI’s Investor Charter requirements.
Regulatory Reporting: Action Taken Reports (ATR) and periodic grievance reports shall be filed with SEBI in the prescribed format and timelines.

This Policy shall be reviewed periodically, or earlier if necessitated by regulatory changes or operational requirements. Updated versions will be approved by the Designated Partners and disclosed on the Company’s website

Date	Details	Version	Approved By
01 April, 26	Policy Introduction	1.0	Designated Partners
14 July, 26	Reviewed	2.0	Designated Partners