About Vistra – SBU for Non-SEBI Regulated Activities

Vistra is a global leader in fiduciary, fund administration, and corporate services, serving clients across multiple jurisdictions with strong governance and regulatory standards. In India, Vistra provides a wide range of financial and administrative services through dedicated business units that operate independently from its SEBI-regulated Debenture Trustee activities.

 In line with SEBI’s Circular dated November 25, 2025 and Regulation 9C of the SEBI (Debenture Trustees) Regulations, 1993, Vistra undertakes certain activities that are not regulated by the Securities and Exchange Board of India (SEBI) through a fully ring-fenced Separate Business Unit (SBU).

Non-SEBI Regulated Activities (SBU) – Disclosure –

The activities listed in this section are not regulated by the Securities and Exchange Board of India (SEBI). Consequently, SEBI’s investor protection mechanisms, including dispute resolution, enforcement, and grievance redressal processes, do not apply to these activities.

List of SBU Activities

The following services are undertaken by Vistra through its Separate Business Unit (SBU) and do not fall within SEBI’s regulatory purview:

• Security Trustee Services
• Escrow Trustee Services
• Multi-Family Office (MFO) Services
• Fund Accounting Services
• Facility Agent Services
• Monitoring Agency Services for other regulated/unregulated products

 (Each of the above activities is delivered as a fee-based, non-fund based financial service.)

Regulatory Note

These services are fee-based, non-fund based, and pertain to the financial services sector. They are undertaken through an independent Separate Business Unit (SBU) that operates with:

• Strict Chinese Walls
• Segregated staff and resources
• A distinct grievance redressal mechanism, and
• Independent processes and record-keeping 

ensuring complete ring-fencing from Vistra’s SEBI-regulated Debenture Trustee activities.

Further, we also want to disclose the attached SEBI circular attached herewith in Ticker form.

Our Strengths

We offer…

• A fully integrated fiduciary service solution 
• Neutrality and independence
• A unique combination of Trusteeship and Advisory services
• A fully integrated Fiduciary Service solution
• Product innovation that is ahead of the curve
• Risk Management that is effective and proactive 
• The know-how of institutional trustees with vast experience in Indian markets
• Global reach through our international presence
• International best practices customised to local requirements
• Expertise in custody, monitoring and compliance metrics

Our Credentials

• Largest non-bank trustee in India
• Two decades of experience in Indian market
• SEBI registered debenture trustee since 2001
• Winner of the Best Corporate Trustee India Award 2015 & 2016 by Wealth and Finance International, UK
• Winner of the Award for Excellence in Corporate Services 2015 – India
• Winner of India’s Best Award 2015 for Business Leadership – Innovation by Skoch Group
• Asset under administration of more than INR 6,855,194 million (US$105.69 billion), audited figure of Financial Year 2017
• Ability to monitor assets across Real Estate, Infrastructure and Financial Services sector
• Seamless default management, coordinated litigation process and the ability to exhibit deterrent action
• 50% market share in the funds trusteeship space
• Strong delivery on security enforcement in public markets 
• Only trustee with experience of monitoring government funds and projects

Our Clients

• Banks and financial intermediaries
• Private equity, venture capital and alternative investment funds
• Foreign financial institutions
• Corporate and overseas bodies
• Government and public institutions
• Pension and mutual Funds
• Insurance companies
• Asset reconstruction companies
• Business owners/ families and non-profit organisations