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Code Of Conduct For Investment Adviser

Code of Conduct (As prescribed under Regulation 15(9) of IA Regulations)

1. Honesty and fairness

  • Act honestly, fairly, and in the best interest of the client.
  • Provide unbiased and independent advice.

2. Diligence

  • Conduct all advisory activities with due skill, care, and professional judgment.
  • Ensure suitability of investment advice based on risk profiling.

3. Capabilities

An investment adviser shall have and employ effectively appropriate resources and procedures which are needed for the efficient performance of its business activities.

4. Information about clients

An investment adviser shall seek from its clients information about their financial situation, investment experience, and investment objectives relevant to the services to be provided, and maintain confidentiality of such information.

5. Information to its clients

An investment adviser shall make adequate disclosures of relevant material information while dealing with its clients.

6. Fair and reasonable charges

  • Identify and disclose all conflicts of interest.
  • Maintain a 100% fee-only advisory model with zero commissions.

7. Conflicts of Interest

An investment adviser shall try to avoid conflicts of interest as far as possible and when they cannot be avoided, it shall ensure that appropriate disclosures are made to the clients and that the clients are fairly treated.

  • Identify and disclose all conflicts of interest.
  • Maintain a 100% fee-only advisory model with zero commissions.

8. Compliance

  • Undertake all activities in compliance with applicable laws.
  • Maintain proper documentation and audit trails.

9. Responsibility of Senior Management

The senior management of a body corporate which is registered as investment adviser shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures by the body corporate.

10. Confidentiality

  • Protect client data and prevent unauthorized access.
  • Do not share client information except as required by law.

11. Professionalism

  • Maintain high standards of knowledge, ethics and behaviour.
  • Follow SEBI regulations, circulars and guidelines without exception.

© 2026 Networth Tracker Solutions Private Limited. All rights reserved.

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Networth Tracker Solutions Private Limited (operating under the brand name Pivot.Money) does not provide any express or implied warranties or guarantees regarding the products and services available on its platform. It shall not be held responsible for any damages or losses arising from the use of, or reliance on, its advisory or related services. Past performance should not be considered as an indicator of future results. Before selecting a fund or creating a portfolio tailored to your needs, please carefully evaluate your individual investment goals, risk tolerance, time horizon, risk-reward preferences, and associated costs. The performance and returns of any investment portfolio cannot be predicted or assured. Investments made based on advisory services carry market risks; therefore, it is important to thoroughly read all scheme-related documents.

© We are registered with the Securities and Exchange Board of India (SEBI) as an Investment Advisor - INA000020396. [Type of Registration: Non-Individual] [Validity of registration: 01-Jul-2025 to Perpetual] AMFI - Registered Mutual Fund Distributor ARN – 333340 | [Validity of registration: 07-Jul-2025 to 06-Jul-2028]

Address: Networth Tracker Solutions Private Limited, 1018, Hubtown Solaris, N. S. Phadke Marg, Saiwadi, Near East West Flyover, Andheri - East, Mumbai – 400 069. [CIN - U66190MH2024PTC424917] [GST No: 27AAJCN6084H1Z2] [Principal Officer details: Mr. Jash Shashin Koradia (jash.k@pivotmoney.app)] [Compliance Officer details: Shashin Koradia (support@pivotmoney.app)] [Corresponding SEBI regional/local office: Plot No. C 4-A, G Block, Near Bank of India, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051]

Copyright © 2025 Pivot.Money is powered by Networth Tracker Solutions Private Limited. All rights reserved.

Networth Tracker Solutions Private Limited (operating under the brand name Pivot.Money) does not provide any express or implied warranties or guarantees regarding the products and services available on its platform. It shall not be held responsible for any damages or losses arising from the use of, or reliance on, its advisory or related services. Past performance should not be considered as an indicator of future results. Before selecting a fund or creating a portfolio tailored to your needs, please carefully evaluate your individual investment goals, risk tolerance, time horizon, risk-reward preferences, and associated costs. The performance and returns of any investment portfolio cannot be predicted or assured. Investments made based on advisory services carry market risks; therefore, it is important to thoroughly read all scheme-related documents.

© We are registered with the Securities and Exchange Board of India (SEBI) as an Investment Advisor - INA000020396. [Type of Registration: Non-Individual] [Validity of registration: 01-Jul-2025 to Perpetual] AMFI - Registered Mutual Fund Distributor ARN – 333340 | [Validity of registration: 07-Jul-2025 to 06-Jul-2028]

Address: Networth Tracker Solutions Private Limited, 1018, Hubtown Solaris, N. S. Phadke Marg, Saiwadi, Near East West Flyover, Andheri - East, Mumbai – 400 069. [CIN - U66190MH2024PTC424917] [GST No: 27AAJCN6084H1Z2] [Principal Officer details: Mr. Jash Shashin Koradia (jash.k@pivotmoney.app)] [Compliance Officer details: Shashin Koradia (support@pivotmoney.app)] [Corresponding SEBI regional/local office: Plot No. C 4-A, G Block, Near Bank of India, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051]

Copyright © 2025 Pivot.Money is powered by Networth Tracker Solutions Private Limited. All rights reserved.