Neomile Asset Managers – Policies & Framework

Code of Conduct

Neomile Asset Managers Pvt Ltd (part of Neomile Group, 100% subsidiary of Neomile Corporate Advisory Ltd) is committed to ethical conduct of business and to achieve this goal, it has introduced the an array of policies – Code of Conduct is part of this integral policy framework for ethical and compliant conduct of business. Click on the below link to access the Code of Conduct –

NAMPL – Code of Conduct

Neomile Growth Fund aims to employ a research based fundamental and macro variable driven research process for undertaking Investments as per the Investment Objective. Click on the below link to access Investment Policy & Processes

NAMPL – Investment Policy & Processes

The Securities and Exchange Board of India (SEBI) vide its circular dated August 27, 2013, inter alia, requires all intermediaries to frame an internal code of conduct to identify and avoid or to deal or manage actual or potential conflict of interest. Further, Securities and Exchange Board of India (SEBI) vide its circular no. CIR/CFD/CMD1/168/2019 dated December 24, 2019, has mandated all the Alternative Investment Funds to follow the Stewardship Code (the Code), as prescribed in Annexure A of SEBI Circular, in relation to its investments in listed equities. As per Principle 2 of the Code, an institutional investor should have a clear policy on how they manage conflict of interest in fulfilling their stewardship responsibilities and publicly disclose it. Click on the below link to access the Conflict of Interest Policy – 

NAMPL – Conflict of Interest Policy

Neomile Investment Managers Private Limited manages SEBI regulated Alternative Investment Funds. Investor service is a vital element for our sustained business growth and we endeavor that our Investors receive great service from us.

Investor feedback and complaints are key to improve our services. Not each difficult interaction with investor is a complaint. Neomile has established principles and framework handle both queries and grievances. Click on the below link to read the Grievance Redressal Policy – 

NAMPL – Grievance Redressal Policy

This Policy is applicable for all the segments including Cash, Equity Derivatives, and Currency Derivatives Segments of Neomile Asset Managers Private Limited (NAMPL). NAMPL is the institutional arm of the Nirmal Bang Group.

SEBI Master Circular on Anti Money Laundering (AML and Combating Financing of Terrorism (CFT) ‐ Obligations of Intermediaries under the Prevention of Money Laundering Act, 2002 and Rules Framed there‐under (Consolidated up to December 31, 2010) and amended as per latest Circular No. CIR/MIRSD/DOP/CIR/P/2019/113 dated 15th October 2019. Click on the below link to access the KYC AML Policy –

NAMPL – KYC AML Policy