Objective

This document outlines the structured, documented, and repeatable process followed by Swaraj FinPro Private Limited (ARN-91802) for identifying, evaluating, and shortlisting mutual fund schemes for client distribution.

Our selection process is based entirely on objective analysis, risk-category mapping, and compliance requirements. Scheme selection is never driven by commission incentives.

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Fund Selection Process Flow

Our fund selection follows this step-by-step process:

Exclusion Criteria

The following are automatically excluded from our recommended list: (a) Schemes from AMCs under SEBI regulatory action or warning; (b) Schemes with high portfolio concentration in a single stock or sector beyond category norms; (c) Debt schemes with significant exposure to below-investment-grade (below AA-) securities; (d) Schemes with more than 2 fund manager changes in the last 3 years; (e) Close-ended or interval schemes unless specifically required for a client's goal; (f) SIF products with opaque strategy or inadequate risk disclosure.

Data Sources

AMC factsheets and monthly portfolio disclosures; Value Research and Morningstar India for performance data and fund ratings; AMFI website for NAV and AUM data; SEBI Riskometer classification for risk categorization; SEBI Mutual Fund filings portal for SID/SAI/KIM documents.

Suitability Mapping

Every shortlisted scheme is mapped to one of three client risk categories: Conservative (score 0-30), Moderate (score 31-60), or Aggressive (score 61-100). No scheme whose SEBI Riskometer category exceeds the client's assessed risk level is recommended. If a client insists on an unsuitable scheme, the Execution-Only process is followed with written unsuitability communication and client consent as per our SOP.

Conflict of Interest Declaration

Swaraj FinPro Private Limited (ARN-91802) is fully independent with no AMC shareholding, employment, directorship, or financial affiliation with any Asset Management Company.

Our fund selection is based solely on objective criteria and is never influenced by commission rates, incentive trips, gifts, or any non-monetary benefits from AMCs.

Our internal audit process (conducted annually) periodically reviews recommendation patterns to identify and eliminate any potential commission bias.