1. Overview
FME 108 Advisors LLP (“FME” or “the LLP”), a limited liability partnership incorporated under the Limited Liability Partnership Act, 2008, is registered with the International Financial Services Centres Authority (“IFSCA” or “Authority”) as a Registered Fund Management Entity (Non-Retail) under the International Financial Services Centres Authority (Fund Management) Regulations, 2025 (“FM Regulations”) vide approval letter dated 5th June 2026. The registration number of the FME is FDM2026FNR1075.
108 BioCapital Growth (GIFT CITY) Fund (“Fund”), a contributory determinate irrevocable trust settled under the Indian Trusts Act, 1882, with Catalyst Trusteeship Limited (acting through its branch in GIFT City) as its trustee (“Trustee”), has been launched by the FME as a Restricted Scheme (Non-Retail) certified as an ‘Alternative Investment Fund – Category II’ under the FM Regulations. The Fund has been granted registration by IFSCA vide approval letter dated 28th July 2026. The registration number of the Fund is IFSC/AIF2/2026-27/0404.
Under the Investment Management Agreement entered into with the Trustee, the FME has been made
responsible for, inter alia, addressing queries, complaints and grievances of the contributors of the Fund
(“Investors” or “Contributors”). Accordingly, all complaints relating to the Fund shall be handled by the FME in accordance with this policy.
In accordance with the IFSCA Circular on “Complaint Handling and Grievance Redressal by Regulated Entities in the IFSC” dated December 02, 2024, and the grievance redressal provisions of the FM Regulations, this policy establishes a structured framework for efficiently addressing investor complaints.
It sets out detailed procedures, resolution timelines, escalation mechanisms, record maintenance
protocols, disclosure requirements, and regulatory reporting obligations.
This policy has been approved by the Designated Partners of the FME to ensure a transparent, fair, and effective grievance redressal mechanism, in compliance with IFSCA regulations, for resolving investor concerns related to the financial services provided by the FME and the Fund.
2. What is a complaint?
A complaint (grievance) is defined under this policy as a written expression of dissatisfaction of the
Investor against the operation of the Fund / FME or its employees, resulting from a potential damage or wrongdoing to an Investor. Investor feedback and queries seeking clarifications shall not be considered as a complaint. This policy provides the framework to be adopted by the FME with respect to effective redressal of complaints. Investor complaints could potentially arise in the normal course of business due to:
Indicative list of what is not treated as a complaint:
3. Complaint Handling Procedure
- a) Any Investor who wishes to file any complaint or grievance can send an email to shom@108.bio or a letter to the address of the FME. The same is reproduced below for ease of reference:
FME 108 Advisors LLP
Unit No. GA-16, Pragya Accelerator, Block-15T, Road-11,
GIFT SEZ, GIFT City, Gandhinagar – 382050, Gujarat, India - b) The email / letter should clearly mention the full facts of the complaint or grievance, along with
supporting documents (if any), for the FME to check, investigate and respond to the complainant. - c) On receipt of a complaint, the CRO shall assess the merits of the complaint. Pursuant to such
assessment:- In case of acceptance, the FME shall acknowledge acceptance of the complaint, in
writing, within 5 working days of receipt of the complaint. - ii. In case of non-acceptance, the FME shall inform the complainant within 7 working days, along with the reasons for non-acceptance.
- iii. The FME shall examine and process the complaint in a fair, transparent, professional and impartial manner.
- Where the CRO is or was involved in the conduct of the financial transaction which is the subject matter of the complaint, the complaint shall be handled by another officer
designated by the CRAO, in a fair and impartial manner. - The FME may seek such additional information from the complainant as may be necessary for reviewing and processing the complaint.
- Upon receipt of such additional information in a timely manner, the FME shall dispose of the complaint preferably within 15 days, but ordinarily not later than 30 days, of acceptance of the complaint.
- The resolution of the complaint, or its rejection along with the reasons for rejection, shall be communicated to the complainant in writing by email / letter.
4. Appeal Mechanism (with the FME)
- If a complainant is not satisfied with the resolution provided, or if the complaint has been rejected, the complainant may file an appeal before the CRAO of the FME, preferably within 21 days of the receipt of the decision from the CRO. The email ID of the CRAO is sasha@108.bio.
- The CRAO shall dispose of the appeal within a period of 30 days.
5. Complaint before the Authority (IFSCA
Where a complainant is not satisfied with the decision provided by the CRO and the CRAO of the FME, the complainant may file a complaint with IFSCA through email to grievance redressal@ifsca.gov.in, preferably within 21 days from the receipt of the decision from the FME.
6. Conciliation and Arbitration
In terms of the Private Placement Memorandum of the Fund, any complaints / disputes not resolved to the satisfaction of the Contributors under the above grievance redressal framework will be resolved through conciliation and / or arbitration process, as may be agreed under the respective Contribution Agreements of the Contributors.
7. Maintenance of Records
The FME shall maintain all records relating to the handling of complaints, including the following:
- Complaints received and processed;
- All correspondence exchanged between the FME and the complainants;
- All information and documents examined and relied upon by the FME while processing the complaints;
- Outcome of the complaints;
- Reasons for rejection of complaints, if any;
- Timelines for processing of complaints; and
- Data of all complaints handled by the FME.
The FME shall maintain the records in electronically retrievable form for the same period as mandated by the Authority under the relevant and applicable regulations, circulars, handbooks and guidelines thereunder.
Provided that in case there is no specific mention of such time period, the records shall be maintained for at least six years from the date of disposal of the complaint:
Provided further that in case of any pending litigation or legal proceeding relating to the complaint, the records shall be maintained for the applicable period after final disposal of the proceeding.
8. Role of Principal Officer and Compliance Officer
The Compliance Officer of the FME shall be responsible for the redressal of investor grievances and shall ensure that the handling and disposal of complaints by the FME are in accordance with the regulatory requirements specified by IFSCA.
The Principal Officer of the FME shall periodically review the investor complaints received and shall ensure immediate redressal of the same by the FME, in accordance with the Code of Conduct specified under the FM Regulations.
9. Disclosure to Investors
The FME shall inform the Investors of the procedure to be followed for grievance redressal. The details of the CRO and the CRAO, along with the grievance redressal mechanism set out in this policy, shall be communicated to the Investors, and shall be updated promptly upon any change.
10. Review
The policy shall be reviewed by the Designated Partners of the FME on a periodic basis, and necessary changes, regulatory or otherwise, shall be carried out and updated in the said policy and shall be recommended to the Designated Partners for their approval.
