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AMFI Code of Conduct for Mutual Fund Distributors

Professional standards, statutory principles, and investor protection guidelines adopted by Sunrise Associates in strict adherence to the Association of Mutual Funds in India (AMFI) and SEBI regulatory directives (Revised April 2022).

Download Official AMFI PDF (April 2022)

1. Purpose and Scope of the Code

This Code of Conduct requires Mutual Fund Distributors (MFDs) to establish high professional standards in their dealings with investors, Asset Management Companies (AMCs), and fellow distributors so as to exemplify the core values of transparency, competency, fairness, and integrity, thereby inspiring and maintaining trustworthiness in the distribution of mutual fund schemes.

This Code is binding upon Sunrise Associates (ARN-92388), its partners, executives, and all personnel engaged in the marketing, sales, and distribution of mutual fund products.

2. Fiduciary Duty & Investor Interest Paramount

  • Investor's Interest Paramount: Sunrise Associates considers the investor's financial interest as paramount, exercising due diligence, proper care, and independent judgment in every scheme interaction.
  • Conflict of Interest Avoidance: We actively avoid conflicts of interest. In any instance where a conflict arises, full disclosure is provided to investors, ensuring equitable and fair treatment.
  • Ethical Recommendations: Financial incentives or distributor commission rates never form the basis for recommending any particular mutual fund scheme or transaction to any investor.
  • Prohibition of Rebates: We strictly refrain from rebating or passing-back commissions to investors, and never attract investors through rebates, gifts, or vouchers.
  • Zero Churning & Ethical Trading: We strictly forbid over-transacting, churning of portfolios to earn commissions, splitting applications, or concealing material facts and risks associated with schemes.

3. Compliance-Related Obligations

  • Regulatory Adherence: Full compliance with SEBI (Mutual Funds) Regulations, 1996, and AMFI circulars regarding marketing, selling, distribution, and performance disclosures.
  • Segregation of Roles: Strict adherence to Regulation 3(3) of SEBI (Investment Advisers) Regulations, 2013, maintaining clear segregation between distribution activities and investment advisory services.
  • KYD & In-Person Verification: Diligent compliance with Know Your Distributor (KYD) norms, document attestation, and In-Person Verification (IPV) under KRA/AMFI rules.
  • Suitability Assessment: Reviewing client financial status, experience, and horizon to ensure suitable scheme distribution.
  • Strict Confidentiality: Maintaining strict confidentiality of all AMC and client data. Zero data-sharing with group companies or third parties for cross-marketing.

4. Infrastructure, Cybersecurity & Record Keeping

  • Digital Infrastructure & Security: Utilizing bank-grade encryption, cybersecurity protocols, and secure transaction execution through official NSE NMF II exchange portals.
  • Internal Controls: Operating internal processes to prevent mis-selling, detect discrepancies, and ensure accurate application processing.
  • Audit Trails & Records: Maintaining comprehensive client application records, transaction feeds, and compliance correspondence as required under SEBI regulations.

5. Client-Related Obligations & Disclosures

  • Full Information Disclosure: Providing investors with authentic scheme documents (SID, SAI, KIM, fact sheets) supplied by AMCs.
  • Highlighting Scheme Risks: Drawing investor attention to market risks, volatility, liquidity conditions, and specific scheme risk factors before investment decisions.
  • Commission Disclosure: In accordance with SEBI guidelines, disclosing all commissions (trail commissions) received or receivable across competing mutual fund schemes.
  • Regular Plans Execution: Categorically disclosing that all investments facilitated on our digital platform are in Regular Plans, involving distributor commission.
  • No Indicative or Assured Returns: Abstaining completely from assuring or indicating fixed returns or guaranteed income on any mutual fund scheme.
  • Grievance Redressal: Dedicated mechanism to promptly address and resolve investor complaints in coordination with AMCs and RTAs.

6. MFD Nomenclature & Professional Qualifications

  • Valid Certifications: Sunrise Associates and its distribution executives hold valid NISM Mutual Fund Distributor certifications and renewed AMFI Registration Numbers (ARN) and EUINs.
  • Statutory Nomenclature: In strict adherence to Regulation 3(3) of SEBI (Investment Advisers) Regulations, 2013, we display the mandatory tagline "AMFI-registered Mutual Fund Distributor" in a clear, legible font of at least font size 12 across all websites, stationary, and communications.
  • Prohibition of Advisory Titles: We never use prohibited titles such as Advisor, Financial Adviser, Wealth Manager, or Consultant in our trade name, designations, or communications.

7. Obligations Towards the Integrity of the Mutual Fund Industry

Sunrise Associates observes the highest standards of professional decorum, providing balanced, factual, and unbiased perspectives without indulging in deceptive advertising or defamatory conduct, consistently upholding public trust in the Indian mutual fund ecosystem.