IMPORTANT INFORMATION: This document contains required regulatory disclosures and material information about Sylivion Investment Management's business practices, conflicts of interest, and investment risks. Please read carefully and retain for your records.
Compliance & Regulatory Transparency
1. Regulatory Positioning
Sylivion Investment Management operates as an independent financial consulting and research firm based in India.
The firm is currently not registered with the Securities and Exchange Board of India (SEBI) as an Investment Adviser, Portfolio Manager, Research Analyst, or Stock Broker.
2. Scope of Services
Financial Strategy Consulting
Market Research & Analytics
Portfolio Structuring Guidance
Investment Education & Advisory Support
Sylivion does not manage client funds, execute trades, or act as a custodian of assets.
All transactions are executed directly by clients through SEBI-registered intermediaries.
3. Risk Disclosure
All investments in securities markets are subject to market risks including potential loss of capital.
Past performance does not guarantee future results.
Clients are advised to perform independent due diligence before making financial decisions.
4. Conflict of Interest Policy
Sylivion maintains transparency in all client engagements and does not accept undisclosed commissions or product-based incentives.
Any potential conflict of interest will be disclosed in writing.
5. Data Protection & Confidentiality
Client information is handled with strict confidentiality and is not shared with third parties without consent, except where required by law.
6. Future Regulatory Intent
Sylivion Investment Management intends to seek appropriate regulatory registrations under SEBI as the firm expands its advisory capabilities.
2. Investment Risk Disclosures
INVESTMENT RISKS: All investments carry risk of loss. You may lose some or all of your principal investment. Past performance does not guarantee future results.
2.1 General Investment Risks
Market Risk: Overall market conditions affect all securities. Market downturns can result in significant losses regardless of individual security performance.
Economic Risk: Economic recessions, inflation, deflation, and changes in monetary policy impact investment values.
Interest Rate Risk: Rising interest rates typically decrease bond prices and may negatively affect certain equity sectors.
Credit Risk: Issuers of debt securities may default on interest or principal payments.
Inflation Risk: Returns may not keep pace with inflation, reducing purchasing power over time.
Liquidity Risk: Some securities may be difficult to sell quickly without accepting a lower price.
Currency Risk: For international investments, exchange rate fluctuations affect returns.
Political and Regulatory Risk: Government actions, policy changes, and political instability affect investment values.
2.2 Asset Class-Specific Risks
Equity Securities (Stocks)
Stock prices can be volatile and may decline significantly
Emerging markets: Political instability, currency volatility, less developed legal systems
3. Fee Disclosures
3.1 Consulting & Advisory Fee Structure
Our standard fee schedule for financial consulting and research services:
Service Type
Fee Structure
One-Time Portfolio Review
₹5,000 – ₹25,000 (Fixed Fee)
Financial Strategy Consultation
₹3,000 – ₹10,000 per session
Monthly Research Subscription
₹2,000 – ₹15,000 per month
Premium Strategy Access
₹25,000 – ₹1,50,000 annually
Customized Financial Planning
Negotiable based on scope and complexity
Key Points:
Fees are based on scope of engagement, complexity, and time involvement
No minimum investment amount is required
Fees are fixed or subscription-based (not percentage of assets managed)
Fees are payable in advance unless otherwise agreed
Refunds, if applicable, are governed by the service agreement
Sylivion does not hold, manage, or custody client funds
3.2 Additional Fees and Expenses
Clients may incur additional third-party costs through their respective brokers or financial institutions. These are not included in Sylivion’s consulting fees:
Brokerage & Trading Charges
Brokerage fees: As per client’s registered broker
Securities Transaction Tax (STT): As per Government of India rates
Exchange transaction charges (NSE/BSE)
SEBI turnover fees
Stamp duty (state dependent)
GST (18%) applicable on brokerage and services
Investment Product Fees
Mutual fund expense ratios: 0.05% – 2.25% annually
ETF expense ratios: 0.03% – 1.00% annually
Portfolio Management Services (if separately hired): As per SEBI-registered PMS provider
Insurance or structured product charges (if applicable)
Margin interest (if applicable): As per broker rates
Bank transaction or payment gateway charges (if applicable)
Regulatory Disclosure:
Sylivion Investment Management is not registered with the Securities and Exchange Board of India (SEBI) as an Investment Adviser, Portfolio Manager, Research Analyst, or Stock Broker. Services are provided strictly on a financial consulting and research basis. All investment decisions are made independently by clients through their respective registered intermediaries.
Important: These additional fees and expenses reduce your net investment returns. A $1,000,000 portfolio with 1.00% advisory fee, 0.25% fund expenses, and 0.10% transaction costs has an effective cost of 1.35% annually, or $13,500 per year.
Important Cost Disclosure
Additional brokerage charges, statutory levies, taxes, and product-level expenses charged by third parties may reduce your net investment returns.
For example, a ₹10,00,000 portfolio with:
Consulting fee of ₹10,000 annually
Mutual fund expense ratio of 0.50%
Estimated brokerage and transaction costs of 0.10%
Would result in total annual costs depending on the products selected and transactions executed by the client.
Actual costs vary based on broker, product type, and market activity.
3.3 Fee Comparison
Our consulting fees may be higher or lower than other financial consultants or SEBI-registered advisors. Factors to consider include:
Level of customization and strategic planning provided
Depth of research and analytics support
Access to financial planning tools
Advisor experience and professional background
Scope of services beyond market commentary
4. Conflicts of Interest
4.1 Proprietary Products
Sylivion Investment Management currently does not operate any SEBI-registered mutual fund, PMS, AIF, or pooled investment vehicle.
If in the future the firm establishes affiliated entities or proprietary strategies, any related-party recommendations will be fully disclosed in writing.
4.2 Research & Platform Relationships
Sylivion may use third-party research tools, data platforms, or analytics software to support financial analysis.
We do not currently receive brokerage-linked soft dollar compensation.
4.3 Third-Party Compensation
Sylivion does not currently receive distribution commissions, 12b-1 fees, revenue sharing payments, or referral-based compensation tied to client investments.
If referral arrangements exist, such relationships will be disclosed transparently before engagement.
4.4 Personal Trading Policy
Employees may maintain personal investment accounts.
Client interests take priority
Front-running of client transactions is strictly prohibited
Confidential client information is protected
4.5 Affiliated Business Entities
Sylivion may collaborate with independent professionals such as accountants, legal advisors, or insurance consultants.
Clients are under no obligation to use any recommended third-party services.
5. Asset Holding & Execution Structure
5.1 Custody of Assets
Sylivion Investment Management does not hold custody of client funds or securities.
All investments are held directly in the client’s name with their chosen SEBI-registered broker, bank, or financial institution.
5.2 Client Control
All investment decisions are implemented by clients through their respective intermediaries.
Sylivion provides non-discretionary strategic guidance only.
6. Performance Reporting
6.1 Performance Presentation
Any performance illustrations shared are hypothetical or model-based unless otherwise specified.
6.2 Past Performance Disclaimer
PAST PERFORMANCE DISCLAIMER:
Past performance is not indicative of future results.
Market conditions, timing, fees, taxation, and investor behavior may significantly impact actual outcomes.
Advisory experience and qualifications of key personnel will be shared upon request.
Sylivion is not currently registered as a SEBI Investment Adviser or Portfolio Manager.
9. Privacy & Cybersecurity
Client data is stored securely
Confidential information is not shared without consent
Reasonable security practices are implemented
10. Complaint & Dispute Resolution
10.1 Internal Resolution
For complaints, contact:
Formal Written Complaint: Submit detailed complaint to:
Sylivion Investment Management
Compliance Desk
Pune, India
Email: compliance@sylivion.com
We will acknowledge complaints within 5 business days and provide substantive response within 30 days.
10.2 Regulatory Note
Since Sylivion is not currently registered under SEBI regulatory categories, clients should consult SEBI-registered professionals for regulated advisory services.
11. Additional Information
Clients may request copies of:
Service Agreement
Fee Schedule
Conflict Disclosure Statement
Privacy Policy
Contact: info@sylivion.com
12. Acknowledgment and Consent
By engaging Sylivion’s services, you acknowledge that:
You understand Sylivion operates as a financial consulting and research firm