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Date: 2026-02-18 Category: Not Applicable State: Union Government Country: India

Zerodha Nifty MidSmallcap400 50:50 Index Fund

Issued by Securities and Exchange Board of India · Not Applicable

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Executive Summary & Key Takeaways

**Executive Summary** This document is a draft Scheme Information Document (SID) for the Zerodha Nifty MidSmallcap400 50:50 Index Fund, an open-ended scheme aiming to replicate/track the Nifty MidSmallcap400 50:50 Index - TRI. The document provides detailed information about the fund's investment objective, asset allocation, risk factors, and other relevant details for prospective investors. The SID is dated February 09, 2026. **Key Points / Main Content** * **Fund Overview:** * The fund is an open-ended scheme replicating/tracking the Nifty MidSmallcap400 50:50 Index - TRI. * The investment objective is to provide returns that closely align with the total returns of the securities constituting the Nifty MidSmallcap400 50:50 Index, subject to tracking error. * The risk-o-meter of the Scheme & the Benchmark (Nifty MidSmallcap400 50:50 Index - TRI) indicates Very High Risk. * **Investment Details:** * Asset allocation will primarily be in equity and equity-related securities covered by the Nifty MidSmallcap400 50:50 Index (95%-100%). * A small portion may be allocated to debt and money market instruments, cash, and cash equivalents (0%-5%). * The fund may invest in derivatives as permitted by SEBI regulations. Investment in derivatives will be upto 20% of the net assets. * The scheme can engage in Stock Lending activities, subject to regulations. Not more than 20% of the total Net Assets will be allocated in Stock Lending. * **NFO & Ongoing Offer Details:** * The New Fund Offer (NFO) period is to be announced, not exceeding 15 days. * During NFO, the offer price is ₹10 per unit. * For both NFO and ongoing periods, the minimum application amount is ₹100 and in multiples of 'any amount' thereafter. * Scheme will reopen for continuous Sale and Repurchase within 05 Business Days from the date of allotment of units under NFO. * Minimum redemption amount shall be 'any amount' or 'any number of units'. * **Systematic Investment Plan (SIP):** * SIP facility is available. * Minimum SIP installment depends on SIP frequency, starting from ₹100. * SIP pause facility available for monthly and quarterly frequencies, with a maximum of 3 consecutive installments that can be paused for SIPs registered with monthly frequency and 1 for quarterly. * **Fees and Expenses:** * Exit Load: Nil. * Maximum Total Expense Ratio (TER): Up to 1.00% of daily net assets. * Transaction charges are not applicable as the scheme is offering only the Direct Plan. * Stamp duty @0.005% of the transaction value is levied on applicable mutual fund transactions. * **Other Key Features:** * Scheme offers only Direct Plan, Growth Option. * Switching, Systematic Transfer Plan (STP), and Systematic Withdrawal Plan (SWP) options are available. * Units can be held in demat or account statement form. **Impact Analysis** **Investors:** *Impact:* Investors seeking long-term capital growth via investments in equity and equity-related securities covered by Nifty MidSmallcap400 50:50 Index will find this fund suitable. They are exposed to "Very High Risk". *Action Required:* Investors should carefully review the SID, consult their financial advisors, and understand the risks before investing. **Zerodha Asset Management Private Limited (AMC):** *Impact:* The AMC is responsible for managing the fund and ensuring compliance with SEBI regulations. *Action Required:* The AMC needs to adhere to the investment restrictions, monitor tracking error, and ensure proper disclosure of information. **Zerodha Trustee Private Limited:** *Impact:* The Trustee is responsible for overseeing the AMC and protecting the interests of the unitholders. *Action Required:* The Trustee needs to ensure that the AMC is managing the fund in accordance with the SID and SEBI regulations. **Unitholders:** *Impact:* The Unit holders can enroll for the SIP facility at the OPA providing this facility during the NFO. *Action Required:* If choosing the SIP facility, investors need to enroll with OPA and provide the bank details and frequency under SIP facility.

Key Entities Referenced

Zerodha Mutual Fund: The mutual fund issuing this scheme. It's the primary entity responsible for managing the fund. Zerodha Nifty MidSmallcap400 50:50 Index Fund: The specific open-ended index fund scheme being detailed in this document, aiming to replicate/track the Nifty MidSmallcap400 50:50 Index - TRI. SEBI (MF) Regulations: The Securities and Exchange Board of India (Mutual Funds) Regulations, 1996, which govern the creation and operation of mutual funds in India and are referenced frequently. Scheme Information Document (SID): The primary document providing information to prospective investors about the scheme. Nifty MidSmallcap400 50:50 Index TRI: The benchmark index that the fund aims to track.
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Draft Scheme Information Document (SID) Zerodha Nifty MidSmallcap400 50:50 Index Fund (An open-ended scheme replicating/ tracking Nifty MidSmallcap400 50:50 Index - TRI)Draft Scheme Information Document SECTION - I Zerodha Nifty MidSmallcap400 50:50 Index Fund (An open-ended scheme replicating/ tracking Nifty MidSmallcap400 50:50 Index - TRI) (Consolidated Std. Obs. 1) Risk-o-meter of the Scheme Risk-o-meter of the Benchmark This product is suitable for investors (Consolidated Std. Obs. 3) (Nifty MidSmallcap400 50:50 who are seeking*: Index - TRI) Long term capital growth Investment in equity and equity related securities covered by Nifty MidSmallcap400 50:50 Index Investors should understand that their principal will be at Very High Risk. *Investors should consult their financial advisers if in doubt about whether the product is suitable for them. The product labelling assigned during the New Fund Offer (NFO) is based on internal assessment of the scheme characteristics or model portfolio and the same may vary post NFO when actual investments are made. (Offer for face value of ₹10/- per unit during New Fund Offer and at continuous offer for units at NAV based prices) ⏺ New Fund Offer opens on ⏺ New Fund Offer closes on Scheme reopens on Scheme will reopen for continuous Sale and Repurchase within 05 Business Days from the date of allotment of units under NFO Name of Sponsor Zerodha Broking Limited Name of Mutual Fund Zerodha Mutual Fund Name of Asset Management Company Zerodha Asset Management Private Limited Name of Trustee Company Zerodha Trustee Private Limited Address Indiqube Penta, New No. 51 (Old No. 14), Richmond Road, Bangalore - 560 025 Website www.zerodhafundhouse.com Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 2The particulars of the Scheme have been prepared in accordance with the Securities and Exchange Board of India (Mutual Funds) Regulations 1996, (hereinafter referred to as ʻSEBI (MF) Regulationsʼ) as amended till date, and filed with SEBI, along with a Due Diligence Certificate from the AMC. The units being offered for public subscription have not been approved or recommended by SEBI nor has SEBI certified the accuracy or adequacy of the Scheme Information Document. The SID sets forth concisely the information about the scheme that a prospective investor ought to know before investing. Before investing, investors should also ascertain about any further changes to this SID after the date of this Document from the Mutual Fund or its Website. The investors are advised to refer to the Statement of Additional Information (SAI) for details of Zerodha Mutual Fund, Standard Risk Factors, Special Considerations, Tax and Legal issues and general information on www.zerodhafundhouse.com . SAI is incorporated by reference (is legally a part of the Scheme Information Document). For a free copy of the SAI, please visit our website or send email to support@zerodhafundhouse.com . The SID should be read in conjunction with the SAI and not in isolation. The Scheme Information Document is dated February 09 , 2026. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 3TABLE OF CONTENTS Particulars Page no. SECTION I I. Highlights/Summary of the Scheme 5-18 Due Diligence by Asset Management Company 19 II. Information about the scheme 20-27 A. How will the scheme allocate its assets? 20-22 B. Where will the scheme invest? 22-23 C. What are the investment strategies? 23-24 D. How will the scheme benchmark its performance? 24 E. Who manages the scheme? 24-25 F. How Is The Scheme Different From Existing Schemes Of The Mutual Fund? 25-26 G. How has the scheme performed? 26 H. Additional Schemes Related Disclosures 27-28 III. Other Details 28-33 A. Computation of NAV 28 B. New Fund Offer Expenses 29 C. Annual Scheme Recurring Expenses 29-32 D. Load Structure 32-33 SECTION II I. Introduction 33-40 A. Definitions/Interpretations 33 B. Risk Factors 33-37 C. Risk Mitigation Strategies 37-41 II. Information about the Scheme 40-75 A. Where will the Scheme Invest 40-44 B. What are the investment restrictions? 44-47 C. Fundamental Attributes 47-48 D. Index methodology 48-64 E. Principles of incentive structure for market makers 65 F. Floors and ceiling within a range of 5% of the intended allocation against each 65 sub class of asset, as per clause 13.6.2 of SEBI master circular for mutual funds dated June 27, 2024. G. Other Scheme Specific Disclosures 66-75 III. Other Details 75-84 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 4Section I I. HIGHLIGHTS OF THE SCHEME Name of the Zerodha Nifty MidSmallcap400 50:50 Index Fund Scheme Category of Scheme Other Schemes - Index Funds Type of Scheme An open-ended scheme replicating/ tracking Nifty MidSmallcap400 50:50 Index - TRI ⏺ Scheme Code (Consolidated Std. Obs. 7) Investment The primary goal is to provide returns that, before expenses, align with the total Objective returns of the securities constituting the Nifty MidSmallcap400 50:50 Index, subject (Consolidated Std. to tracking error. Obs. 26) There is no assurance or guarantee that the investment objective of the scheme would be achieved. (Consolidated Std. Obs. 5) Liquidity On an ongoing basis, the subscription and redemption shall be at NAV based prices on all Business Days. The Fund shall dispatch proceeds of redemption within 03 working days of receiving the valid redemption request. As per SEBI (MF) Regulations, the Mutual Fund shall dispatch redemption proceeds within 03 Business Days from the date of redemption. A penal interest of 15% p.a. or such other rate as may be prescribed by SEBI from time to time, will be paid by the AMC in case the redemption proceeds are not dispatched within 03 Business Days from the date of redemption. Benchmark Nifty MidSmallcap400 50:50 Index TRI (Consolidated Std. Obs. 26) The above Index has been chosen as the benchmark since the Scheme will invest in stocks which are constituents of Nifty MidSmallcap400 50:50 Index. Thus, the aforesaid benchmark is such that it is most suited for comparing the performance of the Scheme. Transparency/ NAV The NAV will be calculated by the AMC for each Business Day except in special Disclosure circumstances. (Standard Observation 17(a)) AMC shall disclose the NAV for each Business Day as below: 1. On the website of the Fund/AMC - 11.00 P.M. of every business day. 2. On the website of Association of Mutual Funds in India (AMFI) - 11.00 P.M. of every business day. Please refer to page no. 77 of Section II for details. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 5Applicable Timelines for Dispatch of redemption proceeds: Timelines As per SEBI (MF) Regulations, the Mutual Fund shall dispatch the redemption or repurchase proceeds to the unitholders within 03 working days from the date of redemption or repurchase. The AMC shall adhere to guidelines published by AMFI/SEBI for exceptional circumstances under which the scheme is unable to transfer redemption or repurchase proceeds within prescribed timelines. Plans and Options The scheme offers only Direct Plan. Plans/Options and The scheme offers only Growth Option. sub options under the Scheme The Trustees/ AMC reserves the right to introduce further Plan/ Options as and when deemed fit, subject to the SEBI (MF) Regulations. For detailed disclosure on default plans and options, kindly refer to SAI. Load Structure Exit Load: Nil The Trustee reserves the right to change/ modify the Load structure of the Scheme, subject to maximum limits as prescribed under the Regulations. For further details on load structure refer to the section ʻ Load Structure ʼ on page no. 32 to 33. Minimum During NFO: Application Amount /Switch In ₹ 100 and in multiples of ʻany amountʼ thereafter. During Ongoing offer period: Investors can invest under the Scheme during the ongoing offer period with a minimum investment of ₹100 and in multiples of ʻany amountʼ thereafter . Minimum During the ongoing offer period, for subsequent additional purchases, the investor Additional can invest with the minimum amount of ₹100 and in multiples of ʻany amountʼ Purchase Amount thereafter . The AMC/ Trustee reserves the right to change/ modify the terms of minimum purchase amount provision offered under the Scheme of the Fund. Minimum The minimum redemption amount shall be ʻany amountʼ or ʻany number of unitsʼ as Redemption/Switch requested by the investor at the time of redemption. Out Amount The redemption would be permitted to the extent of credit balance in the Unit holderʼs account of the Scheme (subject to completion of Lock-in period or release of Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 6pledge / lien or other encumbrances). The Redemption request can be made by specifying the rupee amount or by specifying the number of Units to be redeemed. The AMC/ Trustee reserves the right to change/ modify the terms of minimum redemption amount provision offered under the Scheme of the Fund. Tracking Error “Tracking Error” is defined as the standard deviation of the difference between daily total returns of the underlying index and the NAV of the Scheme. Thus, Tracking Error is the extent to which the NAV of the Scheme moves in a manner inconsistent with the movements of the Schemeʼs benchmark index on any given day or over any given period of time due to any cause or reason whatsoever including but not limited to expenditure incurred by the Scheme, dividend payouts if any, whole cash not invested at all times as the Scheme may keep a portion of funds in cash to meet redemption etc. Regular Plan Direct Plan Not Applicable, since the scheme offers Not Available, since this is a new only Direct Plan. Scheme. Tracking “Tracking Difference” is defined as the annualized difference of daily returns Difference between the benchmark index price and the NAV of the Scheme. Regular Plan Direct Plan Not Applicable, since the scheme offers Not Available, since this is a new only Direct Plan. Scheme. ⏺ New Fund Offer NFO Opens on: (NFO) Period ⏺ NFO Closes on: This is the period during which a new NFO Period for the scheme will be announced at the time of the launch subject to scheme sells its the earlier closure, if any; such offer period not being more than 15 days. units to the investors. In case the NFO Opening/ Closing Date is subsequently declared as a non-Business Day, the following Business Day will be deemed to be the NFO Opening/ Closing Date. Any modification to the New Fund Offer Period shall be announced by way of an Addendum uploaded on the website of the AMC. (Consolidated Std. Obs. 34) The Trustees/ AMC reserves the right to close the NFO before the above-mentioned date by giving notice as per the norms provided under SEBI (MF) Regulations. New Fund Offer Offer of Units at ₹ 10 each during the NFO period of the Scheme. (NFO) Price Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 7(This is the price per Unit that the investors have to pay to invest in NFO) Segregated The Scheme has provided enabling provisions for Creation of Segregated Portfolio in portfolio/ side terms of guidelines issued by SEBI from time to time. pocketing disclosure Please refer to the SAI for the details. (Consolidated Std. Obs. 53) Swing pricing Swing Pricing Framework is Not Applicable for the Scheme. disclosure Please refer to the SAI for more details. Stock lending/short Subject to the Regulations and the applicable guidelines, the Scheme may engage in selling (Standard Stock Lending activities. The Scheme will participate in stock lending not more than Observation 6) 20% of total Net Assets of the Scheme and would limit its exposure with regard to stock lending for a single intermediary to the extent of 5% of the total net assets at the time of lending. Please refer to the SAI for more details. How to Apply and Investors can submit the application for purchase and redemption transactions in other details the schemes of Zerodha Mutual Fund at the Official Points of Acceptance (OPA). The list of OPA is available on the website of AMC i.e., www.zerodhafundhouse.com The investor may also reach out to the investor support email id support@zerodhafundhouse.com for details/ help in investing. Please refer to Page no. 69 of Section II for more details. Investor Services For General service requests Investors can lodge any service request or complaints or enquire about NAVs, Unit Holdings, etc. by sending an email to support@zerodhafundhouse.com . The investor service representatives may seek certain personal information from the investor solely for the purpose of verifying his/her identity and safeguarding the confidentiality of account-related information. The AMC will at all times endeavour to handle transactions efficiently and to resolve any investor grievances promptly. For Complaint Resolution Any complaints should be addressed to the Investor Relations Officer. Address: Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 8Investor Relations Officer Zerodha Asset Management Private Limited New No.51, IndiQube Penta, 2nd Floor, Richmond Road, Bangalore - 560025 Email - iro@zerodhafundhouse.com For any grievances with respect to transactions through BSE StAR/ NMF/ MFSS , the investors / Unit Holders should approach either the stockbroker or the investor grievance cell of the stock exchange. Investors may escalate to the Compliance Officer at compliance@zerodhafundhouse.com and/ or CEO at ceo@zerodhafundhouse.com if they do not receive a response/ not satisfied with the response from the Investor Relations Officer. Specific Attributes Not Applicable. of the Scheme Special During NFO product/facility available during the SYSTEMATIC INVESTMENT PLAN (SIP) NFO and on ongoing basis Unit holders can enroll for the SIP facility at the OPA providing this facility during the NFO. An investor if choosing 29th, 30th or 31st of a month as the SIP date, then the SIP date will be automatically considered as the first business day of the following month. Minimum amount per SIP installment and Minimum number of installments under monthly and quarterly frequency of SIP are as follows: Frequency under SIP Minimum Installment Minimum Amount Facility Daily 01 ₹100 Weekly 01 ₹100 Fortnightly 01 ₹100 Monthly 01 ₹100 Quarterly 01 ₹100 Half-yearly 01 ₹100 Yearly 01 ₹100 If the SIP period whenever asked for is not specified by the unit holder, then the SIP enrolment will be deemed to be for perpetuity and processed accordingly. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 9In case of SIP investments, where the entire installment amount is not available in the bank account, the SIP for that month would be rejected. Allocation to a particular scheme or pro–rata allocation to schemes will not be carried out. Investors may register for SIP through One Time Mandate (OTM) for payment towards any future purchase transactions. Investors may choose any mode such as NACH/ECS/DIRECT DEBIT/ Standing Instruction (SI)/ UPI mandate as per arrangements with banks or payment aggregators. For online transactions, AMC may provide various payment modes, as available from time to time for SIP Enrolments. The SIP registration will be discontinued or considered as closed/ cancelled by the AMC as per the below mentioned timelines: SIP Interval No. of failed attempts prior to cancellations of SIPs Daily 3 Weekly 3 Fortnightly 3 Monthly 3 Quarterly 2 Halfyearly 2 Yearly 2 The AMC/RTA shall send a communication to the investor after 1st failed debit attempt, mentioning that the SIP will cease in case of aforesaid. Units will be allotted at the Applicable NAV on SIP installment realization basis. In case the date falls on a Non-Business Day, the immediate next Business Day will be considered for this purpose. In case the fund is realized on non-business day of the scheme, the immediate next Business Day will be considered for this purpose. The AMC/ Trustee reserves the right to change / modify the terms and conditions of the SIP facility during the NFO period. During Ongoing Offer SYSTEMATIC INVESTMENT PLAN (SIP) Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 10Unit holders can enroll for the SIP facility at the OPA. An investor if choosing 29th, 30th or 31st of a month as the SIP date, then the SIP date will be automatically considered as the first business day of the following month. Minimum amount per SIP installment and Minimum number of installments under monthly and quarterly frequency of SIP are as follows: Frequency under SIP Minimum Installment Minimum Amount Facility Daily 01 ₹100 Weekly 01 ₹100 Fortnightly 01 ₹100 Monthly 01 ₹100 Quarterly 01 ₹100 Half-yearly 01 ₹100 Yearly 01 ₹100 If the SIP period whenever asked for is not specified by the unit holder, then the SIP enrolment will be deemed to be for perpetuity and processed accordingly. In case of SIP investments, where the entire installment amount is not available in the bank account, the SIP for that month would be rejected. Allocation to a particular scheme or pro–rata allocation to schemes will not be carried out. Investors may register for SIP through One Time Mandate (OTM) for payment towards any future purchase transactions. Investors may choose any mode such as NACH/ECS/DIRECT DEBIT/ Standing Instruction (SI)/ UPI mandate as per arrangements with banks or payment aggregators. For online transactions, AMC may provide various payment modes, as available from time to time for SIP Enrolments. The SIP registration will be discontinued or considered as closed/ cancelled by the AMC as per the below mentioned timelines: SIP Interval No. of failed attempts prior to cancellations of SIPs Daily 3 Weekly 3 Fortnightly 3 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 11Monthly 3 Quarterly 2 Halfyearly 2 Yearly 2 The AMC/RTA shall send a communication to the investor after 1st failed debit attempt, mentioning that the SIP will cease in case of aforesaid. Units will be allotted at the Applicable NAV on SIP installment realization basis. In case the date falls on a Non-Business Day, the immediate next Business Day will be considered for this purpose. In case the fund is realized on non-business day of the scheme, the immediate next Business Day will be considered for this purpose. The AMC/ Trustee reserves the right to change / modify the terms and conditions under the SIP prospectively at a future date. SIP Top-up facility Investors may avail fixed SIP Top-up facility where they have an option to increase the amount of the SIP Installment by a fixed amount at predefined intervals. SIP Top-up facility shall be available for SIP Investments through any mode such as NACH/ECS/DIRECT DEBIT/ Standing Instruction (SI)/ UPI mandate as per arrangements with banks or payment aggregators. The Top-up amount should be in multiples of ₹1 only. Monthly and quarterly SIP offers top-up frequency at yearly intervals. An Illustration: How to calculate the SIP Top-up amount? SIP Period : 01-Jan-2023 to 01-Dec-2024 (2 Years) Monthly SIP Installment Amount : ₹ 2,000 SIP Date : 1st of every month (24 installments) Top-up Amount: ₹ 1,000 Top-up Frequency: Yearly SIP Instalments shall be as follows: Installment From Date To Date Monthly SIP Top up Increased No. SIP amount amount in SIP amount in ₹ ₹ in ₹ 1 to 12 01-Jan-23 31-Dec-23 2,000 N.A. 2,000 13 to 24 01-Jan-24 31-Dec-24 2,000 1,000 3,000 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 12Top-up cap option: Unit holders have an option to cap the SIP Top-up amount based on either a fixed predefined amount or date as detailed below: Top-up cap amount: Investor has an option to cap the SIP Top-up amount once the SIP installment (including Top-up amount) reaches a fixed predefined amount. Thereafter the SIP installment will remain constant till the end of SIP tenure. Top-up cap month-year: Investor has an option to provide an end date to the SIP Top-up amount. It is the date from which Top - up to the SIP installment amount will cease and the SIP installment will remain constant till the end of SIP tenure. If none of the above options for Top-up cap is selected by the investor, the SIP Top-up will continue as per the SIP end date and Top-up amount specified by the investor. I l lustration 1: How to fix Top-up cap amount? SIP Period: 01-Jan-2023 to 01-Dec-2027 (5 Years) Monthly SIP Installment Amount: ₹ 2,000 SIP Date: 1st of every month (60 installments) Top-up Amount: ₹ 1,000 Top-up Frequency: Yearly Top-up cap amount (including SIP Installment): ₹ 5,000 Installment From Date To Date Monthly SIP Top up SIP No. SIP amount amount in installment in ₹ ₹ including Top up in ₹ (A) (B) (A+B) 1 to 12 01-Jan-23 31-Dec-23 2,000 N.A. 2,000 13 to 24 01-Jan-24 31-Dec-24 2,000 1,000 3,000 25 to 36 01-Jan-25 31-Dec-25 3,000 1,000 4,000 37 to 48 01-Jan-26 31-Dec-26 4,000 1,000 5,000 49 to 60 01-Jan-27 31-Dec-27 5,000 N.A. 5,000 It may be seen in the above illustration that once the Topup cap amount (including the SIP installment) reaches ₹ 5,000, the SIP installment amount starting January 1, 2027 remains constant. Illustration 2: How to fix top-up cap month-year? Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 13SIP Period: 01-Jan-2023 to 01-Dec-2027 (5 Years) Monthly SIP Installment Amount: ₹ 2,000 SIP Date: 1st of every month (60 installments) Top-up Amount: ₹ 1,000 Top-up Frequency: Yearly Top-up cap month - year: 01-Jan-2026 SIP Instalments shall be as follows: Installment From Date To Date Monthly SIP Top up SIP No. SIP amount amount in installment in ₹ ₹ including Top up in ₹ (A) (B) (A+B) 1 to 12 01-Jan-23 31-Dec-23 2,000 N.A. 2,000 13 to 24 01-Jan-24 31-Dec-24 2,000 1,000 3,000 25 to 36 01-Jan-25 31-Dec-25 3,000 1,000 4,000 37 to 48 01-Jan-26 31-Dec-26 4,000 1,000 5,000 49 to 60 01-Jan-27 31-Dec-27 5,000 N.A. 5,000 It may be seen in the above illustration that after 1-Jan-2026 (the pre- defined Top up cap month-year), the SIP installment amount remains constant. The AMC / Trustee reserves the right to change the terms and conditions of this facility at a later date on a prospective basis. The AMC / Trustee reserves the right to withdraw the SIP Top-up facility. SIP PAUSE FACILITY The Fund offers Systematic Investment Plan (“SIP”) Pause facility (“the Facility”) for investors who wish to temporarily pause their SIP in the Schemes of the Fund. The terms and conditions of the Facility are as follows: 1. This Facility is available for SIPs with Monthly and Quarterly frequencies. 2. The maximum number of installments that can be paused using this facility are 3 (three) consecutive installments for SIPs registered with Monthly frequency and 1 (one) for SIPs registered with Quarterly frequency. Thereafter, automatically the balance SIP installments (as originally registered) will resume. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 143. SIP pause requests should be submitted at least 15 days before the requested start date. 4. SIP Pause once registered cannot be cancelled. 5. The Investor understands and acknowledges that the SIP Pause facility is merely a transaction related facility offered by the Company; and the Investor unconditionally and irrevocably agrees that the AMC or Fund will not be liable for: (i) acting in good faith on any instructions received from the Investor; (ii) any force majeure events that are beyond the control of any person; and (iii) any error, default, delay or inability of the AMC or the Fund or its Agents to act on all or any of the instructions from the Investor. The Investor hereby assumes and undertakes the entire risk of using the Facility and agrees to take full responsibility for the same. The Trustee reserves the right to change / modify the terms and conditions of the Facility or withdraw the Facility. Systematic Transfer Plan (STP) STP is a facility given to the Unit holders to transfer sums on a periodic basis from one scheme to another schemes launched by the Mutual Fund from time to time by giving a single instruction. Investors can opt for the STP by investing a lump sum amount in one scheme of the fund and providing a standing instruction to transfer sums at regular intervals. Particulars Frequency Details Frequency and Transaction Daily Every Business Day Dates Weekly Fortnightly Monthly Minimum number of Daily ₹ 100/- each per transfer transfers and minimum amount per STP Weekly Fortnightly Monthly An investor if choosing 29th, 30th or 31st of a month as the STP date, then the STP date will be automatically considered as the first business day of the following month. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 15If any STP transaction due date falls on a non-Business day, then the respective transactions will be processed on the immediately succeeding Business Day for both the schemes. Default Frequency - Monthly The Trustee/ AMC reserves the right to introduce STPs at any other frequencies or on any other dates as the AMC may feel appropriate from time to time. In the event such a day is a Holiday, the transfer would be affected on the next Business Day. Systematic Withdrawal Plan (SWP) Unit holders have the benefit of availing the choice of Systematic Withdrawal Plan (SWP). The SWP allows the Unit holder to withdraw a specified sum of money each month/quarter/ half-yearly/ yearly from his investments in the Schemes. SWP is ideal for investors seeking a regular inflow of funds for their needs. It is also ideally suited to retirees or individuals, who wish to invest lump sum and withdraw from the investment over a period of time. The amount thus withdrawn by redemption will be converted into Units at Applicable NAV and the number of Units so arrived at will be subtracted from the Units balance to the credit of that Unit holder. The Unit holder may avail of this Option, after the close of the New Fund Offer Period. Unit holders will have the option to change the amount or the period of withdrawals. The SWP may be terminated by a Unit holder and it will terminate automatically if all the Units are liquidated or withdrawn from the account or the holdings fall below Rs.100/- (subject to the Unit holder failing to invest sufficient funds to bring the value of their holdings to the minimum amount of ₹100/- after the completion of SWP, within 30 days after the balance shall have fallen below the minimum holdings) or upon the Mutual Fundʼs receipt of notification of death or incapacity of the first Unit holder. Default Option : Monthly option Minimum SWP installment size is ₹100/- and in multiples of ₹ 1 thereafter. Switching Options Unit holders under the Scheme have the option to switch part or all of their Unit holdings in the Scheme to any other Scheme offered by the Mutual Fund from time to time. The Mutual Fund also provides the investors the flexibility to switch their investments from any other scheme(s) / plan (s) offered by the Mutual Fund to this Scheme. This option will be useful to Unit holders who wish to alter the allocation of their investment among the scheme(s) / plan(s) of the Mutual Fund in order to meet their changed investment needs. The Switch will be affected by way of a Redemption of Units from the Scheme at Applicable NAV, subject to Exit Load, if any and reinvestment of the Redemption proceeds into another Scheme offered by the Mutual Fund at Applicable NAV and accordingly the Switch must comply with the Redemption rules of the Switch out Scheme and the Subscription rules of the Switch in Scheme. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 16OTM – ONE TIME MANDATE (ʻFACILITYʼ) OTM is a simple and convenient facility that enables the Unit holders to transact in the Schemes of the Fund by submitting OTM - One Time Mandate registration with the Fund through e-NACH or UPI autopay facility. It is a one - time registration process wherein the Unit holder(s) of the Scheme(s) of the Fund authorizes his / her bank to debit their account upto a certain specified limit per transaction, on request received from the Fund, as and when the transaction is undertaken by the Unit holder, without the need of submitting cheque or fund transfer letter with every transaction thereafter. This Facility is only available to Unit holder(s) of the Fund who have been assigned a folio number by the AMC. Unit Holder(s) are requested to note that the AMC reserves the right to amend the terms and conditions, or modify, or discontinue the Facility for existing as well as prospective investors at any time in future. Process for Investments made in the name of Minor through a Guardian Payment for investment shall be accepted from the bank account of the minor or from a joint account of the minor with the guardian only, else the transaction is liable to get rejected. Unit holders are requested to review the Bank Account registered in the folio and ensure that the registered Bank Mandate is in favour of minor or joint with registered guardian in folio. If the registered Bank Account is not in favour of minor or not joint with registered guardian, unit holders will be required to submit the change of bank mandate, where minor is also a bank account holder (either single or joint with registered guardian), before initiation any redemption transaction in the folio, else the transaction is liable to get rejected. For systematic transactions in a minorʼs folio, AMC will register standing instructions till the date of the minor attaining majority, though the instructions may be for a period beyond that date. Upon the minor attaining the status of major, the minor in whose name the investment was made, shall be required to provide all the KYC details and updated ban k account details. No further transactions shall be allowed till the status of the minor is changed to major. For further details with respect to the above mentioned products / facilities, kindly refer to SAI. Weblink Total Expense Ratio (TER): ( Consolidated Std.Obs. 26) Please note that this is a new scheme. TER details shall be available from the first NAV date: Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 17The AMC/Mutual Fund shall disclose the Total Expense Ratio (TER) of the Scheme on a daily basis on its website viz. https://www.zerodhafundhouse.com/resources/disclosures/ Scheme Factsheet: Not applicable as the scheme is a new fund to be launched. The AMC on its website viz. https://www.zerodhafundhouse.com/resources/fund-documents will provide a Factsheet of the Scheme on a monthly basis, which contains details such as Fund size, Performance, NAV, etc. IMPORTANT Before investing, investors are requested to also ascertain about any further changes pertaining to scheme such as features, load structure etc. made to this Scheme Information Document by issue of addenda/notice after the date of this Document from the AMC/ Mutual Fund/ Website, etc. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 18F. DUE DILIGENCE BY THE ASSET MANAGEMENT COMPANY (Standard Observation 24) (Consolidated Std. Obs. 55) A Due Diligence Certificate duly signed by the Compliance Officer of Zerodha Asset Management Private Limited has been submitted to SEBI, which reads as follows: It is confirmed that: (i) This Draft Scheme Information Document submitted to SEBI is in accordance with the SEBI (Mutual Funds) Regulations, 1996 (“Regulations”)and the guidelines and directives issued by SEBI from time to time. (ii) All legal requirements connected with the launching of the Scheme as also the guidelines, instructions, etc., issued by the Government and any other competent authority in this behalf, have been duly complied with. (iii) The disclosures made in the Scheme Information Document are true, fair and adequate to enable the investors to make a well-informed decision regarding investment in the proposed Scheme. (iv) The intermediaries named in the Scheme Information Document and Statement of Additional Information are registered with SEBI and their registration is valid, as on date. (v) The contents of the Scheme Information Document including figures, data, yields etc. have been checked and are factually correct (vi) A confirmation that the AMC has complied with the compliance checklist applicable for Scheme Information Documents and other than cited deviations/ that there are no deviations from the regulations (vii) Notwithstanding anything contained in this Scheme Information Document, the provisions of the SEBI (Mutual Funds) Regulations, 1996 and the guidelines thereunder shall be applicable. (viii) The Trustees have ensured that the Zerodha Nifty MidSmallcap400 50:50 Index Fund approved by them is a new product offered by Zerodha Mutual Fund and is not a minor modification of any existing scheme/fund/product. Place: Bengaluru Signed: Sd/- Date: February 09, 2026 Name: Chandra Bhushan Singh Designation: Head Legal & Compliance (Compliance Officer) Note: The due diligence certificate as stated above was submitted to the SEBI on February 09, 2026. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 19II. INFORMATION ABOUT THE SCHEME (Standard Observation 14) A. HOW WILL THE SCHEME ALLOCATE ITS ASSETS? Asset Allocation Under the normal circumstances, the asset allocation (% of Net Assets) of Schemeʼs portfolio will be as follows: Indicative allocations Instruments (% of total assets) Minimum Maximum Equities and equity related securities 95% 100% covered by Nifty MidSmallcap400 50:50 Index Debt and Money Market Instruments, 0% 5% cash and cash equivalents (Consolidated Std. Obs. 21) *Money market instruments include, but are not limited to Treasury Bills, Commercial Paper of Public Sector Undertakings and Private Sector Corporate Entities, Term Money, Tri-party repo, Certificates of Deposit of Scheduled Commercial Banks, Financial Institutions and Development Financial Institutions, Government securities with unexpired maturity of one year or less and other Money Market securities as may be permitted by SEBI / RBI from time to time and in the manner prescribed under the Regulations . In accordance with SEBI circular no. SEBI/HO.IMD/DF2/CIR/P/2021/024 dated March 04, 2021, the cumulative gross exposure through equity and equity instruments, debt, money market instruments and derivative position will not exceed 100% of the net assets of the scheme. (Consolidated Std. Obs. 17) However, cash and cash equivalents with residual maturity of less than 91 days may be treated as not creating any exposure. (Consolidated Std. Obs. 14) The funds raised under the Scheme shall be invested in the stocks and will be as per Regulation 44(1), Schedule 7 of the SEBI (MF) Regulations. The Scheme does not intend to undertake/ invest/ engage in the following: (Consolidated Std. Obs. 18) S.No. Type of Instrument Percentage of Circular references exposure 1. Securitized Debt 2. Short selling of securities 3. Repo in corporate debt 4. Unrated instruments (except TREPs/ Government Securities/ SDL / Repo in The Scheme will not invest/engage in these Government Securities); instruments. 5. Foreign securities/ADR/GDR Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 206. ReITs and InvITs 7. Instruments having Special Features as defined in SEBI Circular no. SEBI/HO/IMD/DF4/CIR/P/2021/032 dated March 10, 2021; 8. Credit Enhancements & Structured Obligations; and 9. Credit Default Swap transactions The scheme shall make investment in derivatives as permitted under the SEBI (MF) regulations. Exposure to equity derivatives of the index or its constituent stocks may be required in certain situations wherein equity shares are unavailable, insufficient or for rebalancing in case of corporate actions within 7 days (or as specified by SEBI from time to time). Investment in derivatives will be upto 20% of the net assets. Subject to the Regulations and the applicable guidelines, the Scheme may engage in Stock Lending activities. The Scheme will participate in stock lending not more than 20% of total Net Assets of the Scheme and would limit its exposure with regard to stock lending for a single intermediary to the extent of 5% of the total net assets at the time of lending. Change in Asset Allocation : The above mentioned investment pattern is indicative and subject to the SEBI (MF) Regulations, the asset allocation pattern indicated above may vary from time to time, on account of receipt of maturity proceeds, interest and/or receipt of subscription. As per SEBI Circular no. SEBI/HO/IMD/DF2/CIR/P/2021/024 dated March 04, 2021, the Fund Manager, may deviate from the above investment pattern for a short term period on defensive considerations. The same will be rebalanced within 7 calendar days and further action may be taken as specified under SEBI Circulars/ AMFI guidelines issued from time to time. Short term defensive consideration: (Consolidated Std. Obs. 23 & 24) Subject to SEBI circular no. SEBI/HO/IMD/DF2/CIR/P/2021/024 dated March 04, 2021 and circulars issued thereunder, the asset allocation pattern indicated above may change for a short term period on defensive considerations, keeping in view market conditions, market opportunities, applicable regulations and political and economic factors. These proportions may vary depending upon the perception of the Fund Manager, the intention being at all times to seek to protect the interests of the Unit holders. Such changes in the investment pattern will be rebalanced within 7 calendar days from the date of deviation and further action may be taken as specified under SEBI Circulars/ AMFI guidelines issued from time to time. Portfolio rebalancing in case of passive breach: (Consolidated Std. Obs. 22) In line with para 3.6.7 of SEBI Master Circular dated June 27, 2024, in case of change in constituents of the index due to periodic review, the portfolio of Scheme shall be rebalanced within 7 calendar days. Further, any transactions undertaken in the portfolio of Index Schemes to meet the redemption and subscription obligations shall be done ensuring that post such transactions replication of the portfolio with the index is maintained at all points of time. However, the portfolio will adhere to the overall investment objectives of the Scheme. However, the same will be rectified at the earliest opportunity as may be available, but not later than 7 calendar days, to minimize the tracking error. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 21Timelines for deployment of Funds mobilized in a New Fund Offer (NFO) Pursuant to SEBI Circular dated February 27, 2025, the funds mobilized during the New Fund Offer (NFO) shall be deployed in accordance with the asset allocation pattern of the scheme within 30 business days from the date of allotment of units. In exceptional cases where the AMC is not able to deploy the funds within this period, shall provide an explanation, including details of the efforts made to deploy the funds, to the Investment Committee of the AMC. The Investment Committee may extend the deployment timeline by up to 30 business days and shall provide recommendations to ensure timely deployment in the future. Portfolio concentration norms In accordance with clause 3.4 of Master Circular, the Index shall comply with the following portfolio concentration norms: (a) The Index shall have a minimum of 10 stocks as its constituents. (b) No single stock shall have more than 25% weight in the Index. (c) The weightage of the top three constituents of the Index, cumulatively shall not be more than 65% of the Index. (d) The individual constituent of the Index shall have a trading frequency greater than or equal to 80% and an average impact cost of 1% or less over the previous six months. The Scheme shall monitor compliance with the aforesaid norms by the Index at the end of every calendar quarter. Further, the updated constituents of the Index will be made available on the website of the Fund. B. WHERE WILL THE SCHEME INVEST? (Standard Observation 15) ( Consolidated Std. Obs. 29) The corpus of the scheme will be invested in Equity and Equity related instruments, and other instruments as may be permitted by SEBI from time to time, which will include but not limited to: 1. Equity and Equity related instruments constituting Nifty MidSmallcap400 50:50 Index and derivatives as may be permitted by SEBI from time to time. 2. Debt and Money Market Instruments*: a. Tri-party repo (TREPS) b. Certificate of Deposit (CD) of scheduled commercial banks and development financial Institutions c. Commercial Paper (CP) d. Treasury Bill (T-Bill) e. Repo f. Securities created and issued by the Central and State Governments g. Non-convertible debentures and bonds h. Floating rate debt instruments i. Investment in Short Term Deposits *Money market instruments include, but are not limited to Treasury Bills, Commercial Paper of Public Sector Undertakings and Private Sector Corporate Entities, Term Money, Tri-party repo, Certificates of Deposit of Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 22Scheduled Commercial Banks, Financial Institutions and Development Financial Institutions, Government securities with unexpired maturity of one year or less and other Money Market securities as may be permitted by SEBI / RBI from time to time and in the manner prescribed under the Regulations. Please refer to Section II in page no. 40 to 44 for more details on the above instruments. C. WHAT ARE THE INVESTMENT STRATEGIES? (Standard Observation 7) ( Consolidated Std. Obs. 26, 27 & 28) The Scheme is a passively managed index fund, which endeavors to invest in stocks in proportion to the weightage of the stocks in the Nifty MidSmallcap400 50:50 Index. The investment strategy would revolve around reducing the tracking error to the least possible extent through regular rebalancing of the portfolio, taking into account the change in weights of stocks in the Index as well as the incremental collections/redemptions in the Scheme. Such rebalancing shall be done in accordance with timelines prescribed by SEBI from time to time. A part of the funds may be invested in debt and money market instruments, to meet the liquidity requirements. The Scheme may also invest in the schemes of Mutual Funds in terms of the prevailing SEBI (MF) Regulations. Though every endeavour will be made to achieve the objective of the Scheme, the AMC/Sponsors/Trustee does not guarantee that the investment objective of the Scheme will be achieved. No guaranteed returns are being offered under the Scheme. EQUITY INVESTMENT STRATEGY: The investment objective of the scheme is to achieve a return equivalent to Nifty MidSmallcap400 50:50 Index by investing in stocks of companies comprising Nifty MidSmallcap400 50:50 Index. The Scheme endeavours to invest in stocks in proportion to the weightages of these stocks in the Nifty MidSmallcap400 50:50 Index. The fund will, in general, invest a significant part of its corpus in equities; the surplus amount of the fund, not exceeding 5% shall be invested in Cash/Tri-Party Repo, Repo in corporate debt securities & Money Market instruments. The performance of the Scheme may not be commensurate with the performance of the respective benchmark of the Schemes on any given day or over any given period. Such variations are commonly referred to as the tracking error. The Scheme intends to maintain a low tracking error by effectively replicating the portfolio in line with the index. However, there is no assurance that all such buying and selling activities would necessarily result in benefit for the Fund. DEBT AND MONEY MARKET INVESTMENT STRATEGY: (Consolidated Std. Obs. 13) Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 23A small portion of the net assets will be held as cash or will be invested in debt and money market instruments permitted by SEBI/RBI including TREPS or in alternative investment for the TREPS as may be provided by the RBI, to meet the liquidity requirements under the Scheme. STRATEGIES FOR INVESTMENT IN DERIVATIVES: The Scheme may take derivatives positions based on the opportunities available subject to the guidelines provided by SEBI from time to time and in line with the overall investment objective of the Scheme. The Scheme intends to use derivatives mainly for the purpose of hedging and portfolio balancing. Losses may arise as a result of using derivatives, but these are likely to be compensated by the gains on the underlying cash instruments held by the Scheme. The Scheme will not assume any leveraged exposure to derivatives. Derivatives can be traded over the exchange or can be structured between two counterparties. PORTFOLIO TURNOVER: Portfolio Turnover is a term used to measure the volume of trading that occurs in a Scheme's portfolio during a given time period. The scheme being an open-ended Debt Index Fund, it is expected that there would be a number of subscriptions and redemptions on a daily basis. Hence, it is difficult to estimate with any reasonable measure of accuracy, the likely turnover in the portfolio. Generally, turnover will depend upon the extent of purchase and redemption of units and the need to rebalance the portfolio on account of change in the composition of the underlying index, if any. The Scheme has no specific target relating to portfolio turnover. The effect of higher portfolio turnover could be higher brokerage and transaction costs (if any). D. HOW WILL THE SCHEME BENCHMARK ITS PERFORMANCE? (Standard Observation 9) The Benchmark for the Scheme is Nifty MidSmallcap400 50:50 Index TRI (Total Returns Index). The above Index has been chosen as the benchmark since the Scheme will invest in stocks which are constituents of Nifty MidSmallcap400 50:50 Index. Thus, the aforesaid benchmark is such that it is most suited for comparing the performance of the Scheme. Please refer to the Section on Index Methodology at Page No . 48 to 65 for more d etails. E. WHO MANAGES THE SCHEME? (Standard Observation 10) (Consolidated Std. Obs. 33) The detail of the Fund Manager of the scheme is as follows: Name and Age Educational Experience Fund (s) Managed Qualification (in years) Kedarnath Mirajkar PGDBM - 20 years 1. Zerodha Nifty LargeMidcap Finance 250 Index Fund 43 Years Zerodha AMC - From “June 2022” Till date Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 242. Zerodha ELSS TaxSaver Aditya Birla Sun Life AMC - Nifty LargeMidcap 250 Index April 2010 to June 2022 Fund 3. Zerodha Nifty 1D Rate Fund Manager/ Dealer Passive - Liquid ETF December 2020 to June 2022 4. Zerodha Nifty Midcap 150 Chief Manager - Risk ETF Management November 2018 5. Zerodha Nifty 100 ETF to December 2020 Trade 6. Zerodha Gold ETF Operations - April 2010 to Nov (Co-Fund Manager) 2018 7. Zerodha Gold ETF FoF 8. Zerodha Silver ETF HDFC Bank (Custody 9. Zerodha Overnight Fund Department) August 2007 to 10. Zerodha Silver ETF FoF March 2010 11. Zerodha Multi Asset Passive FoF Bombay Dyeing - September 12. Zerodha Nifty 8-13 Yr 2005 to August 2007 G-Sec ETF 13. Zerodha Nifty Smallcap 100 ETF 14. Zerodha Nifty 50 Index Fund 15. Zerodha Nifty 50 ETF 16. Zerodha BSE SENSEX Index Fund 17. Zerodha Nifty Short Duration G-Sec Index Fund F. HOW IS THE SCHEME DIFFERENT FROM EXISTING SCHEMES OF THE MUTUAL FUND? Below is the list of all existing schemes of Zerodha Mutual Fund: Scheme Name Type of Scheme Zerodha Nifty LargeMidcap 250 Index Fund An open-ended scheme replicating/ tracking Nifty LargeMidcap 250 Index. Zerodha ELSS Tax Saver Nifty LargeMidcap 250 An open-ended passive equity linked savings Index Fund scheme with a statutory lock-in period of 3 years and tax benefit replicating/ tracking Nifty LargeMidcap 250 Index. Zerodha Nifty 1D Rate Liquid ETF An open-ended Exchange Traded Fund replicating/ tracking Nifty 1D Rate Index. A relatively low interest rate risk and relatively low credit risk. Zerodha Gold ETF An open-ended scheme replicating/tracking domestic price of Physical Gold. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 25Zerodha Nifty 100 ETF An open-ended scheme replicating/tracking Nifty 100 TRI. Zerodha Nifty Midcap 150 ETF An open-ended scheme replicating/tracking Nifty Midcap 150 TRI. Zerodha Gold ETF FoF An open ended fund of fund scheme investing in units of Gold ETF. Zerodha Silver ETF An open ended Exchange Traded Fund replicating/ tracking domestic prices of physical Silver. Zerodha Overnight Fund An open ended debt scheme investing in overnight securities. A Relatively Low Interest Rate Risk and Relatively Low Credit Risk. Zerodha Silver ETF FoF An open ended fund of fund scheme investing in units of Zerodha Silver ETF. Zerodha Multi Asset Passive FoF An open ended fund of fund scheme investing in units of Equity, Debt Index Funds/ ETFs and Commodity ETFs. Zerodha Nifty 8-13 Yr G Sec ETF An open-ended scheme replicating/tracking the Nifty 8-13 Yr G-Sec Index. A Relatively High Interest Rate Risk and Relatively Low Credit Risk. Zerodha Nifty Smallcap 100 ETF An open-ended scheme replicating/tracking Nifty Smallcap 100 TRI. Zerodha Nifty 50 Index Fund An open-ended scheme replicating/ tracking Nifty 50 Index - TRI Zerodha Nifty 50 ETF An open-ended scheme replicating/ tracking Nifty 50 Index - TRI Zerodha BSE SENSEX Index Fund An open-ended scheme replicating/tracking BSE Sensex Index Zerodha Nifty Short Duration G-Sec Index Fund An open-ended scheme replicating/tracking the Nifty Short Duration G-Sec Index. A Moderate Interest Rate Risk and Relatively Low Credit Risk The detailed comparison of the above mentioned existing schemes is disclosed on the website of the AMC viz. https://www.zerodhafundhouse.com/resources/disclosures/ . G. HOW HAS THE SCHEME PERFORMED? This is a new scheme and does not have any performance track record. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 26H. ADDITIONAL SCHEMES RELATED DISCLOSURES I. Scheme Portfolio Holdings: (Consolidated Std. Obs. 26) Please visit the AMC/MF website viz. w ww.zerodhafundhouse.com/resources/disclosures for Top 10 holdings by issuer and the portfolio holdings statements of the scheme. ii. Disclosure of name and exposure to Top 7 issuers, stocks, groups and sectors: Please visit the AMC/MF website viz. w ww.zerodhafundhouse.com/resources/disclosures for details on names and exposure to Top 7 issuers, Groups and Sectors as a percentage of NAV. iii. Functional website link for Portfolio Disclosure - Monthly/ Half Yearly: The Mutual Fund / AMC will disclose the portfolio (along with ISIN and other prescribed/ required details) of the Scheme in the prescribed format, monthly and on a half yearly basis on its website viz. www.zerodhafundhouse.com/resources/disclosures . iv. Portfolio Turnover Rate The Scheme will endeavor to keep the portfolio turnover at a minimum. However, the portfolio turnover ratio may vary as the Scheme may change the portfolio according to Asset Allocation to align itself with the objectives of the Scheme and in accordance with the composition of Nifty MidSmallcap400 50:50 100 Index. The effect of higher portfolio turnover could be higher brokerage and transaction costs. Portfolio Turnover Ratio can be accessed from the website of the AMC viz. www.zerodhafundhouse.com/resources/disclosures . v. Aggregate investment in the Scheme by Concerned Fund Manager(s) : As the scheme is a new scheme, this disclosure requirement is not applicable. For any other disclosure w.r.t investments by key personnel and AMC directors including regulatory provisions in this regard, kindly refer to SAI. vi. Investments of AMC in the Scheme (Standard Observation 1) (Consolidated Std.Obs. 58) In terms of sub-regulation 16(A) in Regulation 25 of SEBI (MF) Regulations read along with SEBI circular no. SEBI/ HO/IMD/IMD - IDOF5/P/CIR/2021/624 dated September 02, 2021 and AMFI Best Practice Guidelines Circular No.100 /2022 - 23 on ʻAlignment of interest of AMCs with the Unitholders of the Mutual Fund schemesʼ, the AMC shall invest such amounts in such schemes of the mutual fund, based on the risks associated with the schemes, as may be specified by the SEBI from time to time. However, as per the circular, ETFs, Index Funds, Overnight Funds, Funds of Funds (FoF) scheme(s) are exempted from the purview of the aforesaid circular. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 27In line with SEBI Regulations and circulars issued by SEBI from time to time, the AMC may invest its own funds in the scheme(s). Further, the AMC shall not charge any fees on its investment in the Scheme (s), unless allowed to do so under SEBI Regulations in the future. III. OTHER DETAILS A. COMPUTATION OF NAV (Consolidated Std. Obs. 42) The Net Asset Value (NAV) per Unit of the Scheme will be computed by dividing the net assets of the Scheme by the number of Units outstanding under the Scheme on the valuation date. The Mutual Fund will value its investments according to the valuation norms, as specified in Schedule VIII of the SEBI (MF) Regulations, or such norms as may be specified by SEBI from time to time. In case of any conflict between the Principles of Fair Valuation and valuation guidelines specified by SEBI, the Principles of Fair Valuation shall prevail. NAV of Units of under the Scheme shall be calculated as shown below: NAV (₹) per Unit = Market or Fair Value of the Schemeʼs Investments + Current Assets - Current Liabilities and Provisions No. of Units outstanding under each Scheme The NAV of the Scheme will be calculated and disclosed at the close of every Business Day. The NAV of the Scheme will be calculated up to 4 decimal places. Methodology for calculation of sale and repurchase price. Pursuant to SEBI circular no. SEBI/HO/IMD/DF2/CIR/P/2018/92 dated June 05, 2018 on “Go Green Initiative in Mutual Funds”, the methodology of calculating the sale and repurchase price of units is explained with an illustration below: A) Sale Price: The Sale Price for a valid purchase will be the Applicable NAV of the respective Scheme i.e. Sale Price = Applicable NAV. For a valid purchase request of ₹ 10,000, where the applicable NAV is ₹ 10, the units will be allotted as below: Purchase Amount - ₹ 10,000 Applicable NAV - ₹ 10 No. of Units - 1,000 Units ( P urchase Amount/Applicable NAV ) Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 28Please note that the entry load has been abolished with effect from August 01, 2009 vide SEBI Circular no.SEBI/IMD/CIR No. 4/ 168230/09 dated August 01, 2009. Hence, Sale price is equal to the applicable NAV. B) Repurchase Price: The Repurchase Price for a valid repurchase will be the applicable NAV reduced by any exit load (say 1%, if redeemed before completion of 1 year). i.e. applicable NAV - (applicable NAV X applicable exit load) For a valid repurchase request where the applicable NAV is ₹ 10, the repurchase price will be as follows : Applicable NAV - ₹ 10 Exit Load - 1% = 10 - (10 X 1%) = 10 - (0.1) = ₹ 9.9 Therefore, for the repurchase for 1,000 units, the Investor will receive the proceeds as given below: No. Of Units - 1,000 Repurchase Price = ₹9.9 =1000 X 9.9 = ₹ 9,900 Note: Transaction charges and other charges/expenses, if any, borne by the investors have not been considered in the above illustration(s). The Mutual Fund will ensure that the Redemption Price will not be lower than 95% of the Applicable NAV provided that the difference between the Redemption Price and the Subscription /Purchase Price at any point in time shall not exceed the permitted limit as prescribed by SEBI from time to time, which is currently 5% calculated on the Subscription/ Purchase Price. The Purchase Price shall be at applicable NAV. (Standard Observation 17(b)) (Consolidated Std. Obs. 47) For other details such as policies w.r.t computation of NAV, rounding off, investment in foreign securities, procedure in case of delay in disclosure of NAV etc. kindly refer to SAI. B. NEW FUND OFFER (NFO) EXPENSES These expenses are incurred for the purpose of various activities related to the NFO like marketing and advertising, Brokerage, registrar expenses, printing and stationery, bank charges etc. The New Fund Offer expenses of the scheme will be borne by the AMC. C. ANNUAL SCHEME RECURRING EXPENSES Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 29These are the fees and expenses incurred for the Scheme. These expenses include but are not limited to Investment Management and Advisory Fee charged by the AMC, Registrar and Transfer Agents' fee, marketing and selling costs, listing fee, etc. The AMC has estimated that the following expenses will be charged to the Scheme as permitted under Regulation 52 of SEBI (MF) Regulations. For the actual current expenses being charged, the investor should refer to the website of the Mutual Fund viz. www.zerodhafundhouse.com Expense Head % of daily net assets (estimated) (p.a.) Investment Management and Advisory Fees Upto 1.00% Audit fees/fees and expenses of trustees 1 Custodial Fees Registrar & Transfer Agent Fees including cost of providing account statements / IDCW / redemption cheques/ warrants Marketing & Selling Expenses including Agents Commission and statutory advertisement Cost related to Investor Communication Cost of fund transfer from one location to another Cost towards investor education and awareness 2 Brokerage and Transaction cost over and above 0.12% and 0.05% on value of trades for cash and derivative market trades only GST on expenses other than Investment Management and Advisory Fees 3 GST on brokerage and transaction cost 3 Other Expenses Maximum Total Expense Ratio (TER) permissible under Regulation 52 (6) 4 Upto 1.00% 1 Trustee Fees and Expenses In accordance with the Trust Deed constituting the Mutual Fund, the Trustee is entitled to receive, in addition to the reimbursement of all costs, charges, and expenses, a fee of upto INR 15,00,000 per quarter (aggregate across all schemes), to be allocated to individual schemes in proportion to their average AUM for the preceding quarter. 2 Investor Education and Awareness initiatives (Consolidated Std. Obs. 43) As per Para F of the SEBI Circular No. CIR/IMD/DF/21/2012 dated September 13, 2012 read with SEBI Circular no. SEBI/HO/IMD/DOF2/P/CIR/2022/69 dated May 23, 2022, the AMC shall annually set apart at least 1 basis points p.a. (i.e. 0.01% p.a.) on daily net assets of the Plan(s) under the Scheme within the limits of total expenses prescribed under Regulation 52 of SEBI (MF) Regulations for investor education and awareness initiatives undertaken. 3 Refer Point (3) below on GST on various expenses. 4 The expenses towards Investment Management and Advisory Fees under Regulation 52 (2) and the various sub-heads of recurring expenses mentioned under Regulation 52 (4) of SEBI (MF) Regulations are fungible in Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 30nature. Thus, there shall be no internal sub-limits within the expense ratio for expense heads mentioned under Regulation 52 (2) and (4) respectively. The purpose of the above table is to assist the Investor in understanding the various costs and expenses that an Investor in the Plan(s) under the Scheme will bear directly or indirectly. The figures in the table above are estimates. The actual expenses that can be charged to the Scheme will be subject to limits prescribed from time to time under the SEBI (MF) Regulations. GST As per Para B of the SEBI circular no. CIR/IMD/DF/21/2012 dated September 13, 2012, GST shall be charged as follows: - a. GST on investment management and advisory fees shall be charged to the Scheme in addition to the maximum limit of TER as prescribed in Regulation 52 (6) of the SEBI (MF) Regulations. b. GST on other than investment management and advisory fees, if any, shall be borne by the Scheme within the maximum limit of TER as prescribed in Regulation 52 (6) of the SEBI (MF) Regulations. c. GST on brokerage and transaction cost paid for execution of trade, if any, shall be within the limit prescribed under Regulation 52 of the SEBI (MF) Regulations. The total expenses of the Scheme including the Investment Management and Advisory Fee shall not exceed the limits stated in Regulation 52 of the SEBI (MF) Regulations. The mutual fund would update the current expense ratios on the website ( www.zerodhafundhouse.com ) at least three working days prior to the effective date of the change and update the TER under the Section titled “Statutory Disclosures” under the sub-section titl e d “Total Expense Ratio of Mutual Funds”. Illustration: Impact of Expense Ratio on Scheme's return (Consolidated Std. Obs. 44) Expense ratio, normally expressed as a percentage of Average Assets under Management, is calculated by dividing the permissible expenses under the Regulations by the average net assets. To further illustrate the above, for the Scheme under reference, suppose an Investor invested ₹ 10,000/- (after deduction of stamp duty) under the Direct Plan, the impact of 1% expenses charged will be as under: Particulars Direct Plan Amount invested at the beginning of the year 10,000 (Rs.) Returns before expenses (Rs.) 1,500 Expenses (Rs.) 115 Returns after expenses at the end of the year 11,385 (Rs.) Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 31Returns (per annum in %) 13.85% Note(s): - The purpose of the above illustration is to purely explain the impact of expense ratio charged to the Plan(s) under the Scheme and should not be construed as providing any kind of investment advice or guarantee of returns on investments. - It is assumed that the expenses charged are evenly distributed throughout the year. - Calculations are based on assumed NAVs, and actual returns on your investment may be more, or less. - Any tax impact has not been considered in the above example, in view of the individual nature of the tax implications. Each investor is advised to seek appropriate advice. All scheme related expenses including commission paid to distributors, by whatever name it may be called and in whatever manner it may be paid, shall necessarily paid from the scheme only within the regulatory limits and not from the books of AMC, its associate, sponsor, trustees or any other entity through any route in terms of SEBI circulars, subject to the clarifications provided by SEBI to AMFI vide letter dated February 21, 2019 on implementation of SEBI Circular dated October 22, 2018 on Total Expense Ratio (TER) and performance disclosure for Mutual Fund. D. LOAD STRUCTURE (Consolidated Std. Obs. 47) Exit Load is an amount which is paid by the investor to redeem the units from the scheme. Load amounts are variable and are subject to change from time to time. For the current applicable structure, please refer to the website of the AMC ( w ww.zerodhafundhouse.com ). Details of Load Structure: Type of Load Load Chargeable (% of NAV) Exit / Redemption Load Nil The Trustee / AMC reserves the right to modify / change the Load structure if it so deems fit in the interest of smooth and efficient functioning of the Mutual Fund. Any imposition or enhancement of Exit Load in the load shall be applicable on prospective investments only. At the time of changing the load structure the AMC / Mutual Fund may adopt the following procedure: (Standard Observation 16) (i) The addendum detailing the changes will be attached to Scheme Information Document and Key Information Memorandum and displayed on our website www.zerodhafundhouse.com . [Standard Observation 16(i)] (ii) The introduction of the Load along with the details will be mentioned in the acknowledgement issued to the investors on submission of the application and will also be disclosed in the Account Statement or in the covering letter issued to the Unit holders after the introduction of such Load. (iii) A public notice shall be given in respect of such changes in one English daily newspaper having nationwide circulation as well as in a newspaper published in the language of the region where Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 32the Head Office of the Mutual Fund is situated. Any other measures which the mutual fund may feel necessary. [Standard Observation 16(iii)] (iv) Any other measures which the mutual fund may feel necessary. [Standard Observation 16(iv)] SECTION - II I. Introduction A. Definitions/Interpretations In this Scheme Information Document, the words and expressions shall have the meaning specified in the following link, unless the context otherwise requires. https://www.zerodhafundhouse.com/resources/disclosures/ B. Risk Factors (Standard Observation 2) (Consolidated Std. Obs. 8) Standard Risk Factors - Investment in Mutual Fund Units involves investment risks such as trading volumes, settlement risk, liquidity risk, default risk including the possible loss of principal. - As the price/ value/ interest rates of the securities in which the Scheme invests fluctuates, the value of your investment in the Scheme may go up or down depending on the various factors and forces affecting the capital markets and money markets. - Past performance of the Sponsors and their affiliates / AMC / Mutual Fund does not guarantee future performance of the Scheme of the Mutual Fund. - The name of the Scheme does not in any manner indicate either the quality of the Scheme or its future prospects and returns. - The Sponsors are not responsible or liable for any loss resulting from the operation of the Scheme beyond the initial contribution of ₹1 lakh each made by them towards setting up the Fund. - The present Scheme is not a guaranteed or assured return Scheme. Scheme Specific Risk Factors The Scheme is subject to the specific risks that may adversely affect the Schemeʼs NAV, return and / or ability to meet its investment objective. The specific risk factors related to the Scheme include, but are not limited to the following: ● Tracking Error/ Tracking Difference Risk: (Consolidated Std. Obs. 10) (Consolidated Std. Obs. 39) The Fund Manager would not be able to invest the entire corpus exactly in the same proportion as in the underlying index due to certain factors such as the fees and expenses of the Scheme, corporate actions, cash balance, changes to the underlying index, regulatory restrictions and lack of liquidity which may result in Tracking Error. Hence it may affect Schemeʼs ability to achieve close correlation with the underlying index of the Scheme. The Schemeʼs returns may therefore deviate from its Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 33underlying index. The Fund Manager would monitor the Tracking Error of the Scheme on an ongoing basis and would seek to minimize the Tracking Error to the maximum extent possible. Tracking errors are inherent in any index fund and such errors may cause the scheme to generate returns which are not in line with the performance of the Nifty MidSmallcap400 50:50 Index or one or more securities covered by / included in the Nifty MidSmallcap400 50:50 Index and may arise from a variety of factors including but not limited to: 1. Any delay in the purchase or sale of securities due to illiquidity in the market, settlement and realisation of sales proceeds, delay in credit of securities or in receipt and consequent reinvestment of dividend, etc. 2. The index reflects the prices of securities at a point in time, which is the price at close of business day on the stock exchange. The scheme, however, may trade the securities at different points in time during the trading session and therefore the prices at which the scheme trades may not be identical to the closing price of each scrip on that day on the respective stock exchange. In addition, the scheme may opt to trade the same securities on different exchanges due to price or liquidity factors, which may also result in traded prices being at variance from the closing price considered in the Index. 3. The potential of trades to fail may result in the scheme not having acquired the security at the price necessary to mirror the index. 4. Transaction and other expenses, such as but not limited to brokerage, custody, trustee and investment management fees. 5. Being an open-ended passive scheme, the scheme may hold appropriate levels of cash or cash equivalents to meet ongoing redemptions. 6. The scheme may not be able to acquire or sell the desired number of securities due to conditions prevailing in the securities market, such as, but not restricted to circuit filters in the securities, liquidity and volatility in security prices. The tracking error of the scheme based on past one year rolling data shall not exceed 2%. In case of unavoidable circumstances in the nature of force majeure, which are beyond the control of the AMCs/ Mutual Fund, the tracking error may exceed 2% and the same shall be brought to the notice of Trustees with corrective actions taken by the AMC, if any. The Scheme will disclose the tracking error based on past one year rolling data, on a daily basis, on the website of AMC and AMFI. In case the Scheme has been in existence for a period of less than one year, the annualized standard deviation shall be calculated based on available data. Risks associated with Equity and Equity Related Instruments : Equity and equity related instruments by nature are volatile and prone to price fluctuations on a daily basis due to macro and micro economic factors. The value of Equity and Equity Related Instruments may fluctuate due to factors affecting the securities markets such as price volatility, volumes traded, interest rates, currency exchange rates, changes in law/policies of the Government, taxation laws, political, economic or other developments, which may have an adverse impact on individual securities, a specific sector or all sectors. Consequently, the NAV of the Units issued under the Scheme may be adversely affected. Equity and Equity related instruments listed on the stock exchange carry lower liquidity risk; however the Schemeʼs ability to sell these investments is limited by the overall trading volume on the stock exchanges. In certain cases, settlement periods may be extended significantly by unforeseen Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 34circumstances. The inability of the Scheme to make intended securities purchases due to settlement problems could cause the Scheme to miss certain investment opportunities. Similarly, the inability to sell securities held in the Schemeʼs portfolio may result, at times, in potential losses to the Scheme, if there is a subsequent decline in the value of securities held in the Schemeʼs portfolio. Investments in equity and equity related instruments involve a degree of risk and investors should not invest in the Scheme unless they can afford to take the risk of losing their investment. Risks associated with Debt and Money Market Instruments or Fixed Income Securities Debt and Money Market Instruments or Fixed Income Securities are subject to the risk of an issuerʼs inability to meet interest and principal payments on its obligations and market perception of the creditworthiness of the issuer. Credit Risk: This is the risk associated with the issuer of a debenture/bond or a Money Market Instrument defaulting on coupon payments or in paying back the principal amount on maturity. Even when there is no default, the price of a security may change with expected changes in the credit rating of the issuer. It is to be noted here that a Government Security is a sovereign security and is the safest. Corporate bonds carry a higher amount of credit risk than Government Securities. Within corporate bonds also there are different levels of safety and a bond rated higher by a particular rating agency is safer than a bond rated lower by the same rating agency. Interest-Rate Risk: Fixed income securities such as government bonds, corporate bonds and Money Market Instruments run price-risk or interest-rate risk. Generally, when interest rates rise, prices of existing fixed income securities fall and when interest rates drop, such prices increase. The extent of fall or rise in the prices depends upon the coupon and maturity of the security. It also depends upon the yield level at which the security is being traded. Liquidity Risk: The Indian debt market is such that a large percentage of the total traded volumes on particular days might be concentrated in a few securities. Traded volumes for particular securities differ significantly on a daily basis. Consequently, the scheme might have to incur a significant “impact cost” while transacting large volumes in a particular security. Reinvestment Risk: Investments in fixed income securities carry reinvestment risk as interest rates prevailing on the coupon payment or maturity dates may differ from the original coupon of the bond. Basis Risk: The underlying benchmark of a floating rate security or a swap might become less active or may cease to exist and thus may not be able to capture the exact interest rate movements. This may result in loss of value of the portfolio. Spread Risk: In a floating rate security the coupon is expressed in terms of a spread or mark up over the benchmark rate. During the tenure of the security this spread may move adversely or favourably leading to fluctuations in value of the portfolio. The yield of the underlying benchmark might not change, but the spread of the security over the underlying benchmark might increase leading to loss in value of the security. Risk of Rating Migration: It may be noted that the price of a rated security would be impacted with the change in rating and hence, there is risk associated with such migration. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 35Counterparty and Settlement Risk: Corporate Bond Repo will be settled between two counterparties in the OTC segment unlike in the case of TREPS transactions where CCIL stands as central counterparty on all transactions (no settlement risk).Settlement risk in reverse repo will be mitigated by requiring the counterparty (entity borrowing funds from the Mutual Fund) to deliver the defined collateral in the account of the MF before the cash is lent to the counterparty. Further, the Mutual Fund will also have a limited universe of counterparties, but not limited to, comprising Scheduled Commercial Banks, Primary Dealers, Mutual Funds and National Financial Institutions. Legislative Risk: Changes in government policy in general and changes in tax benefits applicable to Mutual Funds may impact the returns to investors in the scheme. Risk factors associated with processing of transactions through Stock Exchange Mechanism The trading mechanism introduced by the Stock Exchange(s) is configured to accept and process transactions for mutual fund Units in both Physical and Demat Form. The allotment and/or redemption of Units through NSE and/or BSE or any other authorised Stock Exchange(s), on any Business Day will depend upon the modalities of processing viz. collection of application form, order processing /settlement, etc. upon which the Fund has no control. Moreover, transactions conducted through the Stock Exchange mechanism shall be governed by the operating guidelines and directives issued by respective recognized Stock Exchange(s). Accordingly, there could be negative impacts to the investors such as delay or failure in allotment / redemption of units. The Fund and the AMC are not responsible for the negative impacts. Risk associated with Securities Lending (Standard Observation 6) Securities Lending is a lending of securities through an approved intermediary to a borrower under an agreement for a specified period with the condition that the borrower will return equivalent securities of the same type or class at the end of the specified period along with the corporate benefits accruing on the securities borrowed. There are risks inherent in securities lending, including the risk of failure of the other party, in this case the approved intermediary to comply with the terms of the agreement. Such failure can result in a possible loss of rights to the collateral, the inability of the approved intermediary to return the securities deposited by the lender and the possible loss of corporate benefits accruing thereon. The AMC shall adhere to the following limits should it engage in Stock Lending: 1. Not more than 20% of the net assets of a Scheme can generally be deployed in Stock Lending. 2. Not more than 5% of the net assets of a Scheme can generally be deployed in Stock Lending to any single approved intermediary / counterparty. Risk associated with Derivatives (Standard Observation 5) Derivative products are leveraged instruments and can provide disproportionate gains as well as disproportionate losses to the investor. Execution of such strategies depends upon the ability of the Fund Manager to identify such opportunities. Identification and execution of the strategies to be pursued by the fund manager involve uncertainty and decision of the fund manager may not always be Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 36profitable. No assurance can be given that the fund manager will be able to identify or execute such strategies. The risks associated with the use of derivatives are different from or possibly greater than, the risks associated with investing directly in securities and other traditional investments. Trading in derivatives has the following risks: 1. An exposure to derivatives in excess of the hedging requirements can lead to losses. 2. An exposure to derivatives, when used for hedging purpose, can also limit the profits from a genuine investment transaction. 3. Derivatives carry the risk of adverse changes in the market price. 4. Illiquidity Risk i.e., risk that a derivative trade may not be executed or reversed quickly enough at a fair price, due to lack of liquidity in the market. The Fund may use derivatives instruments like equity futures & options, or other derivative instruments as permitted under the Regulations and Guidelines. Usage of derivatives will expose the Scheme to liquidity risk, open position risk, and opportunities risk etc. Such risks include the risk of mispricing or improper valuation and the inability of derivatives to correlate perfectly with underlying assets, rates and indices. In case of the derivative strategies, it may not be possible to square off the cash position against the corresponding derivative position at the exact closing price available in the Value Weighted Average Period. Debt derivatives instruments like interest rate swaps, forward rate agreements or other derivative instruments also involve certain risks. C. Risk Mitigation Strategies (Consolidated Std. Obs. 9) The Scheme aims to track the Nifty Midsmallcap400 50:50 Index TRI before expenses. The Index is tracked on a regular basis and changes to the constituents or their weights, if any, are replicated in the Underlying Portfolio with the purpose of minimising tracking errors. Investments in equity, debt and money market securities carry various risks such as but not limited to the ones mentioned above. Whilst such risks cannot be eliminated, they may be mitigated by diversification. In order to mitigate the various risks, the portfolio of the Scheme will be constructed in accordance with the investment restriction specified under the Regulations which would help in mitigating certain risks relating to investments in the securities market. The AMC incorporates necessary framework in place for risk mitigation at an enterprise level, and scheme level in accordance with the Risk Management Framework prescribed by the SEBI. The Risk Management division of the AMC is an independent division within the organisation. Internal risk thresholds are defined and judiciously monitored. Risk indicators on various parameters are computed and are monitored on a regular basis. The Risk Management Committee of the Board enables a dedicated focus on risk factors and the relevant risk mitigants from time to time. Equity Investments Risk & Description Risk mitigants / management strategy Market Risk: The Scheme is Market risk is inherent to an equity scheme. Being a passively vulnerable to movements in managed scheme, it will invest in the securities included in its Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 37the prices of securities Underlying Index. invested by the Scheme, which could have a material bearing on the overall returns from the Scheme. Liquidity risk: The liquidity As such the liquidity of securities that the scheme invests into could of the Schemeʼs be relatively low. The Scheme will try to maintain a proper investments is inherently asset-liability match to ensure redemption payments are made on restricted by the trading time. volumes in the securities in which the scheme invests as per the Underlying Index. Volatility risk: The equity Over 95% of the scheme will invest in securities in line with the Nifty markets and derivative Midsmallcap400 50:50 Index and will thus have a similar volatility markets are volatile and profile as the index. The volatility of the debt & money market the value of securities, portion of the portfolio will be controlled by diversification. derivative contracts and other instruments correlated with the equity markets may fluctuate dramatically from day to day. This volatility may cause the value of investment in the Scheme to decrease. Derivative risk: As and when The investment managers will invest only in exchange traded the Scheme trades in the derivatives and the investment shall be in line with guidelines derivatives market there and regulatory limits as specified by regulators & scheme are risk factors and issues documents. No investment will be made in OTC derivative contracts concerning the use of for equity derivatives. derivatives since derivative products are specialized instruments that require investment techniques and risk analyses different from those associated with stocks and bond. Concentration risk: The risk Over 95% of the scheme will invest in securities in line with the Nifty of the scheme investing Midsmallcap400 50:50 Index and will thus have a similar heavily in a particular concentration profile as the index. The concentration of the debt sector, asset class, or a & money market portion of the portfolio will be controlled by small number of diversification. companies. If that specific Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 38area underperforms, the fund's value can suffer disproportionately. Tracking Error: The The Investment Manager would monitor the tracking error of the performance of the Scheme Scheme on an ongoing basis and would seek to minimise tracking may not be commensurate error to the maximum extent possible. The investment manager will with the performance of the endeavour to maintain low cash levels to minimise tracking error. benchmark index on any given day or over any given period, referred to as tracking error. Securities Lending: All securities lending and borrowing transactions are carried out Securities Lending is a through the SLB platform of the recognized stock exchanges. The lending of securities Scheme adheres to the limits prescribed by SEBI for securities through an approved lending. intermediary to a borrower under an agreement for a specified period with the condition that the borrower will return equivalent securities of the same type or class at the end of the specified period along with the corporate benefits accruing on the securities borrowed. Processing of transactions The AMC has established appropriate internal controls, monitoring through Stock Exchange mechanisms, and reconciliation processes to manage risks Mechanism: transactions associated with transactions processed through the Stock Exchange conducted through the mechanism. Stock Exchange mechanism shall be governed by the operating guidelines and directives issued by respective recognized Stock Exchange(s). Accordingly, there could be negative impacts to the investors such as delay or failure in allotment / redemption of units. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 39Debt Investments Risk & Description Risk mitigants / management strategy Market Risk/Interest Rate In a rising interest rate scenario, the Scheme may increase its Risk: As with all debt investment in money market securities whereas if the interest securities, changes in rates are expected to fall, the allocation to debt securities with interest rates may affect the longer maturity may be increased thereby mitigating risk to that Schemeʼs Net Asset Value as extent. the prices of securities generally increase as interest rates decline and generally decrease as interest rates rise. Prices of long-term securities generally fluctuate more in response to interest rate changes than do short-Term securities. Indian debt markets can be volatile leading to the possibility of price movements up or down in fixed income securities and thereby to possible movements in the NAV. Credit Risk: Credit risk or Managementʼs past track record will also be studied. In order to default risk refers to the risk assess financial risk a detailed assessment of the issuerʼs financial that an issuer of a fixed statements will be undertaken to review its ability to undergo income security may default stress on cash flows and asset quality. A detailed evaluation of (i.e., will be unable to make accounting policies, off-balance sheet exposures, notes, auditorsʼ timely principal and interest comments and disclosure standards will also be made to assess payments on the security). the overall financial risk of the potential borrower. Normally, the value of a fixed income security will In case of securitized debt instruments, the Scheme will ensure fluctuate depending upon that these instruments are sufficiently backed by assets. the changes in the perceived level of credit risk as well as any actual event of default. The greater the credit risk, the greater the yield required for someone to be compensated for the increased risk. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 40Liquidity risk: This refers to The Scheme may invest in government securities, corporate the ease with which a bonds and money market instruments. While the liquidity risk for security can be sold at or government securities, money market instruments and short near to its valuation maturity corporate bonds may be low, it may be high in case of yield-to-maturity (YTM) medium to long maturity corporate bonds Reinvestment risk: This risk Reinvestment risk will only apply to the small portion of the refers to the interest rate portfolio made up of coupon payments from debt instruments, levels at which cash flows thus limiting its overall impact. received from the securities in the Schemes are reinvested. The risk is that the rate at which interim cash flows can be reinvested may be lower than that originally assumed. Debt and Money Market • Basis Risk: Securities invested in are fixed rate securities and instruments: Debt and hence basis risk does not apply. This risk is generally associated Money Market Instruments with floating rate securities and has a higher bearing on long-term or Fixed Income Securities securities. are subject to the risk of an issuerʼs inability to meet • Spread Risk: Securities invested in are fixed rate securities and interest and principal hence spread risk does not apply. This risk is generally associated payments on its obligations with floating rate securities and has a higher bearing on long-term and market perception of securities. the creditworthiness of the issuer. • Risk of Rating Migration: TREPS and Sovereign securities do not have rating and other eligible money market instruments and overnight funds the scheme have time to maturity lower than 91 days which results in a very low probability of rating migration. This risk is generally associated with long-term securities. • Counterparty and Settlement Risk: Settlement risk in reverse repo will be mitigated by requiring the counterparty (entity borrowing funds from the Mutual Fund) to deliver the defined collateral in the account of the MF before the cash is lent to the counterparty. • Legislative Risk: The Fund Manager maintains the flexibility to rebalance the portfolio in response to policy shifts (e.g., changes in sector-specific subsidies or import/export duties) to protect the scheme's capital and optimize returns. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 41II. Information about the Scheme A. Where will the Scheme Invest (Standard Observation 15) (Consolidated Std. Obs. 13 and 29) The corpus of the Scheme shall be invested in accordance with the investment objective in any (but not exclusively) of the following securities, subject to the Regulations: Equity and Equity related instruments: Equity and Equity related Securities of companies constituting Nifty MidSmallcap400 50:50 Index. Debt and Money Market Instruments : Listed debt or money market securities, in accordance with seventh schedule to the SEBI (MF) Regulations, SEBI circular no. SEBI/HO/IMD/DF2/CIR/P/2019/104 dated October 01, 2019 and other guidelines/ circulars as may be amended from time to time. Tri-party repo (TREPS) Tri-party repo means a repo contract where a third entity (apart from the borrower and lender), called a TriParty Agent, acts as an intermediary between the two parties to the repo to facilitate services like collateral selection, payment and settlement, custody and management during the life of the transaction. TREPS facilitates borrowing and lending of funds, in a Tri-Party Repo arrangement. Certificate of Deposit (CD) of scheduled commercial banks and development financial Institutions Certificate of Deposit (CD) is a negotiable money market instrument issued by scheduled commercial banks and select all-India Financial Institutions that have been permitted by the RBI to raise short term resources. The maturity period of CDs issued by the Banks is between 7 days to one year. Commercial Paper (CP) Commercial Paper (CP) is an unsecured negotiable money market instrument issued in the form of a promissory note, generally issued by the corporates, primary dealers and All India Financial Institutions as an alternative source of short-term borrowings. CP is traded in the secondary market and can be freely bought and sold before maturity. Treasury Bill (T-Bill) Treasury Bills (T-Bills) are issued by the Government of India to meet their short-term borrowing requirements. T-Bills are generally issued for maturities of 7 days, 14 days, 91 days, 182 days and 364 days. Repo Repo (Repurchase Agreement) or Reverse Repo is a transaction in which two parties agree to sell and purchase the same security with an agreement to purchase or sell the same security at a mutually decided future date and price. The transaction results in collateralized borrowing or lending of funds. Presently in India, G-Secs, State Government securities and T-Bills are eligible for Repo/Reverse Repo. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 42Securities created and issued by the Central and State Governments as may be permitted by RBI, securities guaranteed by the Central and State Governments (including but not limited to coupon bearing bonds, zero coupon bonds and treasury bills). State Government securities (popularly known as State Development Loans or SDLs) are issued by the respective State Government in coordination with the RBI. Non-convertible debentures and bonds Non-convertible debentures as well as bonds are securities issued by companies / Institutions promoted / owned by the Central or State Governments and statutory bodies which may or may not carry a Central/State Government guarantee, Public and private sector banks, all India Financial Institutions and Private Sector Companies. These instruments may be secured or unsecured against the assets of the Company and generally issued to meet the short term and long-term fund requirements. The Scheme may also invest in the non-convertible part of convertible debt securities. Floating rate debt instruments Floating rate debt instruments are instruments issued by Central / state governments, corporates, PSUs, etc. with interest rates that are reset periodically. Investment in Short Term Deposits Pending deployment of funds as per the investment objective of the Scheme, the Funds may be parked in short term deposits of the Scheduled Commercial Banks, subject to guidelines and limits specified by SEBI. The securities / instruments mentioned above and such other securities the Scheme is permitted to invest in could be listed, unlisted, privately placed, secured, unsecured, rated or unrated and of any maturity. The securities may be acquired through initial public offering (IPOs), secondary market, private placement, rights offers, negotiated deals. Further investments in debentures, bonds and other fixed income securities will be in instruments which have been assigned investment grade rating by the Credit Rating Agency. Investment in unrated debt instruments shall be subject to complying with the provisions of the Regulations and within the limit as specified in Schedule VII to the Regulations. Pursuant to SEBI Circular No. MFD/CIR/9/120/2000 dated November 24, 2000; the AMC may constitute committee(s) to approve proposals for investments in unrated debt instruments. The AMC Board and the Trustee shall approve the detailed parameters for such investments. However, in case any unrated debt security does not fall under the parameters, the prior approval of the Board of AMC and Trustee shall be sought. Investments in Debt and Money Market Instruments will be as per the limits specified in the asset allocation table(s) of the Scheme, subject to permissible limits laid under SEBI (MF) Regulations from time to time. For applicable regulatory investment limits please refer to below paragraph "What are the Investment Restrictions”. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 43Investment in Derivatives The Scheme may take derivatives positions based on the opportunities available subject to the guidelines provided by SEBI from time to time and in line with the overall investment objective of the Scheme. Derivatives can be traded over the exchange or can be structured between two counterparties. Those transacted over the exchange are called Exchange Traded derivatives whereas the other category is referred to as OTC (Over the Counter) derivatives. Pursuant to clause 7.5.1.2 of SEBI Master Circular dated June 27, 2024, the Mutual Fund Scheme(s) shall be treated as Trading Members at par with a registered FII in respect of position limits in index futures, index options, stock options and stock futures contracts. The position limits for trading in derivatives by Mutual Funds specified by clause 7.5 of the Master Circular are as follows: i. Position limit for Mutual Funds in index options contracts a. The Mutual Fund position limit in all index options contracts on a particular underlying index shall be Rs. 250 crore or 15% of the total open interest of the market in index options, whichever is higher, per Stock Exchange. b. This limit would be applicable on open positions in all options contracts on a particular underlying index. ii. Position limit for Mutual Funds in index futures contracts a. The Mutual Fund position limit in all index futures contracts on a particular underlying index shall be Rs. 250 crore or 15% of the total open interest of the market in index futures, whichever is higher, per Stock Exchange. b. This limit would be applicable on open positions in all futures contracts on a particular underlying index. iii. Additional position limit for hedging In addition to the position limits at point (i) and (ii) above, Mutual Funds may take exposure in equity index derivatives subject to the following limits: 1. Short positions in index derivatives (short futures, short calls and long puts) shall not exceed (in notional value) the Mutual Fundʼs holding of stocks. 2. Long positions in index derivatives (long futures, long calls and short puts) shall not exceed (in notional value) the Mutual Fundʼs holding of cash, government securities, T-Bills and similar instruments. iv. Position limit for Mutual Funds for stock based derivative contracts The Mutual Fund position limit in a derivative contract on a particular underlying stock, i.e. stock option contracts and stock futures contracts, stand modified in the following manner: 1. For stocks in which the market wide position limit is less than or equal to Rs. 250 crore, the Mutual Fund position limit in such stock shall be 20% of the market wide position limit. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 442. For stocks in which the market wide position limit is greater than Rs. 250 crore, the Mutual Fund position limit in such stock shall be Rs. 50 crore. v. Position limit for each scheme of a Mutual Fund The position limits for each scheme of mutual fund and disclosure requirements shall be identical to that prescribed for a sub-account of a FII. Therefore, the scheme-wise position limit / disclosure requirements shall be: 1. For stock option and stock futures contracts, the gross open position across all derivative contracts on a particular underlying stock of a scheme of a mutual fund shall not exceed the higher of: ● 1% of the free float market capitalisation (in terms of number of shares); or ● 5% of the open interest in the derivative contracts on a particular underlying stock (in terms of number of contracts). 2. These position limits shall be applicable on the combined position in all derivative contracts on an underlying stock at a Stock Exchange. 3. For index based contracts, Mutual Funds shall disclose the total open interest held by its scheme or all schemes put together in a particular underlying index, if such open interest equals to or exceeds 15% of the open interest of all derivative contracts on that underlying index. For applicable regulatory investment limits please refer to below paragraph "What are the Investment Restrictions”. B. What are the investment restrictions? (Standard Observation 11) As per the Regulations, the following investment restrictions are currently applicable to the Scheme (all investment restrictions shall be applicable at the time of making investment): - The Mutual Fund shall buy and sell securities on the basis of deliveries and shall in all cases of purchases, take delivery of relevant securities and in all cases of sale, deliver the securities. - The mutual fund shall get the securities purchased or transferred in the name of the mutual fund on account of the Scheme, wherever investments are intended to be of long-term nature. - Save as otherwise expressly provided under SEBI (MF) Regulations, the Mutual Fund shall not advance any loans for any purpose. - As per SEBI (MF) Regulations, the mutual fund under all its Scheme(s) will not own more than 10% of any companyʼs paid-up capital carrying voting rights. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 45Provided that the Sponsor of the Fund, its associate or group company including the asset management company of the Fund, through the Scheme(s) of the Fund or otherwise, individually or collectively, directly or indirectly, shall not have 10% or more of the share- holding or voting rights in the asset management company or the trustee company of any other mutual fund. Provided further that in the event of a merger, acquisition, scheme of arrangement or any other arrangement involving the sponsors of the mutual funds, shareholders of the asset management companies or trustee companies, their associates or group companies which results in the incidental acquisition of shares, voting rights or representation on the board of the asset management companies or trustee companies beyond the above specified limit, such exposure may be rebalanced within a period of one year of coming into force of such an arrangement. - The Scheme shall only invest in equity shares or equity related instruments which are listed or to be listed. - The Scheme shall not make any investment in: ● Any unlisted security of an associate or group company of the Sponsor; or ● Any security issued by way of private placement by an associate or group company of the Sponsor; or ● The listed securities of group companies of the Sponsor, which is in excess of 25% of the net assets of the Scheme of the Fund. ● any Fund of funds Scheme. - The cumulative gross exposure through all permissible investments viz. equity, debt and money market positions should not exceed 100% of the net assets of the Scheme. - The Scheme shall not invest in unlisted debt instruments including commercial papers, except Government Securities and other money market instruments. Provided that the Scheme may invest in unlisted non-convertible debentures up to a maximum of 10% of the debt portfolio of the Scheme subject to such conditions as may be specified by SEBI from time to time. Provided further that the Scheme shall comply with the norms under the above clauses within the time and in the manner as may be specified by SEBI. Provided further that the norms for investments by the Scheme in unrated debt instruments shall be as specified by SEBI from time to time. - Further, the Scheme shall comply with provisions of SEBI Circular No. SEBI/HO/IMD/DF2/ CIR/P/ 2019/104 dated October 1, 2019 regarding investment in Debt and Money Market Instruments, as amended from time to time, to the extent applicable to the Scheme. - The Scheme shall not invest more than 10% of its NAV in debt instruments comprising money market instruments and non-money market instruments issued by a single issuer which are rated not below investment grade by a credit rating agency authorised to carry out such activity under the Act. Such investment limit may be extended to 12% of the NAV of the Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 46scheme with the prior approval of the Board of Trustees and the Board of directors of the asset management company. Provided that such limit shall not be applicable for investments in Government Securities, treasury bills and Tri-Party Repos. Provided further that investment within such limit can be made in mortgaged backed securitised debt which are rated not below investment grade by a credit rating agency registered with the Board. Considering the nature of the Scheme, investments in such instruments will be permitted up to 5% of its NAV. - The Scheme shall invest in Debt instruments having Structured Obligations/ Credit Enhancements in accordance with provisions of SEBI Circular No. SEBI/HO/ IMD/DF2/CIR/P/ 2019/104 dated October 1, 2019 as may be amended by SEBI from time to time. The same are currently as under: The investment of the Scheme in the following instruments shall not exceed 10% of the debt portfolio of the Scheme and the group exposure in such instruments shall not exceed 5% of the debt portfolio of the Scheme: a. Unsupported rating of debt instruments (i.e. without factoring-in credit enhancements) is below investment grade; and b. Supported rating of debt instruments (i.e. after factoring-in credit enhancement) is above investment grade. For this purpose, a group means a group as defined under regulation 2 (mm) of the Regulations and shall include an entity, its subsidiaries, fellow subsidiaries, its holding company and its associates. However, the above Investment limits shall not be applicable on investments in securitized debt instruments, as defined in SEBI (Public Offer and Listing of Securitized Debt Instruments) Regulations 2008. Investment in debt instruments, having credit enhancements backed by equity shares directly or indirectly, shall have a minimum cover of 4 times considering the market value of such shares. - Transfer of investments from one Scheme to another Scheme in the same mutual fund, shall be allowed only if: a) such transfers are made at the prevailing market price for quoted Securities on spot basis. Explanation: spot basis shall have the same meaning as specified by Stock exchange for spot transactions. Provided that inter scheme transfer of money market or debt security (irrespective of maturity) shall take place based on prices made available by valuation agencies as prescribed by SEBI from time to time. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 47b) the securities so transferred shall be in conformity with the investment objective of the Scheme to which such transfer has been made. c) inter Scheme Transfers are affected in accordance with the guidelines specified by SEBI circular No. SEBI/ HO/ IMD/DF4/CIR/P/2020/202 dated October 08, 2020 as amended from time to time. ( Consolidated Std. Obs. 30 & 59) - The Scheme may invest in other scheme(s) under the same AMC or any other mutual fund without charging any fees, provided that aggregate inter-scheme investment made by all Schemes under the same AMC or in Schemes under the management of any other asset management shall not exceed 5% of the net asset value of the Mutual Fund. Further, the Scheme shall not invest in any fund of funds scheme. - Pending deployment of funds of the Scheme in securities in terms of the investment objectives of the Scheme, the Fund may invest the funds of the Scheme in short term deposits of scheduled commercial banks subject to the following guidelines as specified by SEBI: ● “Short Term” for parking of funds shall be treated as a period not exceeding 91 days. ● Short Term deposits shall be held in the name of the Scheme. ● Total investment of the Scheme in short term deposit(s) of all the Scheduled Commercial Banks put together shall not exceed 15% of the net assets. However, this limit can be raised up to 20% of the net assets with prior approval of the Board of Trustees. ● Investments in short term deposits of associate and sponsor scheduled commercial banks together shall not exceed 20% of total deployment by the Mutual Fund in short term deposits. ● The Scheme shall not invest more than 10% of the net assets in short term deposit(s) of any one scheduled commercial bank including its subsidiaries. ● The Scheme shall not invest in short term deposits of a bank which has invested in the Scheme. Trustees/ AMC shall also take steps to ensure that a bank in which the Scheme has short term deposit does not invest in the Scheme until the Scheme has short term deposit with such bank. ● No investment management and advisory fees will be charged for such investments in the Scheme. ● The aforesaid limits shall not be applicable to term deposits placed as margin for trading in the cash market. ● However, the period for ʻpending deploymentʼ as stated above for the Scheme shall not exceed 7 days. The AMC may alter these above stated restrictions from time to time to the extent the SEBI (MF) Regulations change, so as to permit the Scheme to make its investments in the full spectrum of permitted investments for mutual funds to achieve its respective investment objective. The Trustee may from time to time alter these restrictions in conformity with the SEBI (MF) Regulations. Further, apart from the investment restrictions prescribed under SEBI (MF) Regulations, the Fund may follow any internal norms vis-à-vis restricting / limiting exposure to a particular scrip or sector, etc. (Standard Observation 13) (Consolidated Std. Obs. 19) Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 48C. Fundamental Attributes (Standard Observation 8) (Consolidated Std. Obs. 59) Following are the fundamental attributes of the Scheme, in terms of Regulation 18 (15A) of the SEBI (MF) Regulations: (i) Type of scheme: An open-ended scheme replicating/ tracking Nifty MidSmallcap400 50:50 Index - TRI. (ii) Investment Objective: a) Main Objective - The primary goal is to provide returns that, before expenses, align with the total returns of the securities represented by the An open-ended scheme replicating/ tracking Nifty MidSmallcap400 50:50 Index - TRI, subject to tracking error. b) Investment Pattern - Please refer to the section“ H ow will the scheme allocate its assets?” (iii) Terms of Issue: a) Liquidity provisions such as listing, repurchase, redemption. Please refer to the section “Highlights/Summary of the Scheme.” b) Aggregate fees and expenses charged to the Scheme. Please refer, section “Annual Scheme Recurring Expenses.” c) Any safety net or guarantee provided - Not Applicable. Change in Fundamental Attributes: In accordance with Regulation 18 (15A) of the SEBI (MF) Regulations, the Trustee shall ensure that no change in the fundamental attributes of the Scheme and the Option thereunder or the trust or fee and expenses payable or any other change which would modify the Scheme and the Option thereunder and affect the interest of Unit holders is carried out by the AMC, unless it complies with sub-regulation (26) of Regulation 25 of the SEBI (MF) Regulations. Further, in accordance with Regulation 25 (26) of the SEBI (MF) Regulations, the AMC shall ensure that no change in the fundamental attributes of the Scheme or the trust or fee and expenses payable or any other change which would modify the Scheme and affect the interests of Unitholders shall be carried out unless: (i) A written communication about the proposed change is sent to each Unitholder and an advertisement is issued in one English daily newspaper having nationwide circulation as well as in a newspaper published in the language of the region where the Head Office of the Mutual Fund is situated; and (ii) The Unitholders are given an option for a period of atleast 30 calendar days to exit at the prevailing Net Asset Value without any exit load. D. Index methodology The performance of the scheme will be benchmarked against the Nifty MidSmallcap400 50:50 Index - TRI. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 49The Scheme proposes to invest in equity and equity related instruments of companies, which are constituents of the Nifty MidSmallcap400 50:50 Index. Hence, it is an appropriate benchmark for the Scheme. Further, a Total Returns Index reflects the returns on the index from index gain/loss plus dividend payments by constituent index stocks. The performance will be benchmarked to the Total Returns Variant of the Index. The Trustee reserves the right to change the benchmark for evaluation of performance of the Scheme from time to time in conformity with the investment objectives and appropriateness of the benchmark subject to SEBI (MF) Regulations, and other prevailing guidelines, if any by suitable notification to investors to this effect. About the Index The Nifty MidSmallcap400 50:50 Index is a capped version of the Nifty MidSmallcap400 Index. The mid cap segment represented by stocks forming part of the Nifty Midcap 150 and the small cap segment represented by stocks forming part of the Nifty Smallcap 250 are equally weighted. The weight of each stock within the segment is based on free float market capitalization. Highlights ● The index has a base date of April 01, 2005 and a base value of 1000. ● The index is reconstituted semi-annually and rebalanced quarterly. ● The weight of each stock within the segment is based on free float market capitalization. Index rebalancing: Semi-annually The constituents of Nifty MidSmallcap400 50:50 Index a s on February 05, 2026 and impact cost as on December 31, 2025: S.NO. SECURITY NAME WEIGHTAGE IMPACT COST 1 BSE Ltd. 1.58 0.03 2 Multi Commodity Exchange of India Ltd. 1.58 0.02 3 Hero MotoCorp Ltd. 1.00 0.02 4 Laurus Labs Ltd. 0.96 0.03 5 Federal Bank Ltd. 0.95 0.02 6 Persistent Systems Ltd. 0.87 0.03 7 IndusInd Bank Ltd. 0.81 0.02 8 Cummins India Ltd. 0.79 0.02 9 Suzlon Energy Ltd. 0.78 0.02 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 5010 Ashok Leyland Ltd. 0.77 0.02 11 Indus Towers Ltd. 0.77 0.04 12 Karur Vysya Bank Ltd. 0.76 0.04 13 IDFC First Bank Ltd. 0.76 0.03 14 HDFC Asset Management Company Ltd. 0.75 0.02 15 AU Small Finance Bank Ltd. 0.74 0.03 16 Lupin Ltd. 0.72 0.02 17 Coforge Ltd. 0.72 0.03 18 PB Fintech Ltd. 0.71 0.03 19 One 97 Communications Ltd. 0.66 0.02 20 Dixon Technologies (India) Ltd. 0.63 0.02 21 Central Depository Services (India) Ltd. 0.62 0.03 22 Delhivery Ltd. 0.62 0.03 23 Max Financial Services Ltd. 0.60 0.02 24 Fortis Healthcare Ltd. 0.60 0.03 25 Navin Fluorine International Ltd. 0.59 0.05 26 Hindustan Petroleum Corporation Ltd. 0.59 0.02 27 GE Vernova T&D India Ltd. 0.58 0.07 28 Swiggy Ltd. 0.57 0.03 29 SRF Ltd. 0.56 0.03 30 Bharat Forge Ltd. 0.56 0.03 31 UPL Ltd. 0.56 0.03 32 Radico Khaitan Ltd 0.56 0.04 33 City Union Bank Ltd. 0.54 0.04 34 Polycab India Ltd. 0.53 0.02 35 APL Apollo Tubes Ltd. 0.53 0.04 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 5136 Marico Ltd. 0.53 0.02 37 Muthoot Finance Ltd. 0.51 0.04 38 Hindustan Copper Ltd. 0.51 0.04 39 Yes Bank Ltd. 0.50 0.03 40 Sundaram Finance Ltd. 0.49 0.04 41 FSN E-Commerce Ventures Ltd. 0.47 0.03 42 RBL Bank Ltd. 0.47 0.04 43 GMR Airports Ltd. 0.46 0.03 44 Bharat Heavy Electricals Ltd. 0.46 0.03 45 Union Bank of India 0.46 0.03 46 Computer Age Management Services Ltd. 0.45 0.02 47 Alkem Laboratories Ltd. 0.44 0.03 48 Aurobindo Pharma Ltd. 0.44 0.02 49 Angel One Ltd. 0.44 0.02 50 National Aluminium Co. Ltd. 0.44 0.02 51 Voltas Ltd. 0.43 0.03 52 Cholamandalam Financial Holdings Ltd. 0.43 0.06 53 Phoenix Mills Ltd. 0.43 0.03 54 Indian Bank 0.42 0.03 55 Manappuram Finance Ltd. 0.42 0.04 56 Vodafone Idea Ltd. 0.41 0.08 57 PNB Housing Finance Ltd. 0.41 0.03 58 Redington Ltd. 0.41 0.05 59 Crompton Greaves Consumer Electricals 0.41 0.04 Ltd. 60 MphasiS Ltd. 0.40 0.03 61 Dabur India Ltd. 0.40 0.02 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 5262 Glenmark Pharmaceuticals Ltd. 0.40 0.04 63 Waaree Energies Ltd. 0.39 0.03 64 NMDC Ltd. 0.39 0.03 65 J.B. Chemicals & Pharmaceuticals Ltd. 0.39 0.04 66 360 ONE WAM Ltd. 0.39 0.04 67 Krishna Institute of Medical Sciences Ltd. 0.38 0.05 68 Gland Pharma Ltd. 0.38 0.05 69 The Ramco Cements Ltd. 0.38 0.05 70 Colgate Palmolive (India) Ltd. 0.37 0.03 71 KEI Industries Ltd. 0.37 0.03 72 MRF Ltd. 0.37 0.03 73 Oil India Ltd. 0.36 0.03 74 Torrent Power Ltd. 0.36 0.04 75 Biocon Ltd. 0.36 0.03 76 Amber Enterprises India Ltd. 0.36 0.03 77 Bandhan Bank Ltd. 0.36 0.03 78 Coromandel International Ltd. 0.36 0.03 79 Aditya Birla Capital Ltd. 0.35 0.04 80 Vishal Mega Mart Ltd. 0.35 0.04 81 Prestige Estates Projects Ltd. 0.34 0.04 82 ICICI Prudential Life Insurance Company 0.34 0.04 Ltd. 83 PI Industries Ltd. 0.34 0.04 84 Tube Investments of India Ltd. 0.34 0.03 85 Kfin Technologies Ltd. 0.34 0.04 86 Authum Investment & Infrastructure Ltd. 0.34 0.06 87 NHPC Ltd. 0.34 0.03 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 5388 Godrej Properties Ltd. 0.34 0.04 89 Jindal Stainless Ltd. 0.33 0.05 90 Mahindra & Mahindra Financial Services 0.33 0.04 Ltd. 91 Hitachi Energy India Ltd. 0.33 0.04 92 Blue Star Ltd. 0.32 0.03 93 Kalpataru Projects International Ltd. 0.32 0.05 94 Supreme Industries Ltd. 0.32 0.03 95 Great Eastern Shipping Co. Ltd. 0.32 0.05 96 Anand Rathi Wealth Ltd. 0.32 0.06 97 Aster DM Healthcare Ltd. 0.32 0.04 98 J.K. Cement Ltd. 0.32 0.04 99 Mankind Pharma Ltd. 0.31 0.03 100 Sona BLW Precision Forgings Ltd. 0.31 0.03 101 L&T Finance Ltd. 0.31 0.04 102 Steel Authority of India Ltd. 0.31 0.02 103 Poonawalla Fincorp Ltd. 0.30 0.04 104 Narayana Hrudayalaya Ltd. 0.30 0.05 105 Asahi India Glass Ltd. 0.30 0.06 106 IIFL Finance Ltd. 0.30 0.04 107 Page Industries Ltd. 0.30 0.03 108 SBI Cards and Payment Services Ltd. 0.30 0.04 109 Petronet LNG Ltd. 0.30 0.03 110 UNO Minda Ltd. 0.30 0.04 111 Wockhardt Ltd. 0.30 0.05 112 Timken India Ltd. 0.29 0.06 113 ZF Commercial Vehicle Control Systems 0.29 0.08 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 54India Ltd. 114 Motherson Sumi Wiring India Ltd. 0.29 0.05 115 Neuland Laboratories Ltd. 0.29 0.04 116 Kaynes Technology India Ltd. 0.29 0.03 117 Sammaan Capital Ltd. 0.29 0.05 118 Balkrishna Industries Ltd. 0.29 0.04 119 Sai Life Sciences Ltd. 0.29 0.06 120 Jubilant Foodworks Ltd. 0.29 0.04 121 Tata Chemicals Ltd. 0.29 0.03 122 Welspun Corp Ltd. 0.28 0.05 123 Dr. Lal Path Labs Ltd. 0.28 0.05 124 Star Health and Allied Insurance Company 0.28 0.05 Ltd. 125 Amara Raja Energy & Mobility Ltd. 0.28 0.03 126 Brigade Enterprises Ltd. 0.28 0.06 127 Himadri Speciality Chemical Ltd. 0.27 0.05 128 PTC Industries Ltd. 0.27 0.07 129 Affle 3i Ltd. 0.27 0.05 130 Elgi Equipments Ltd. 0.27 0.05 131 Nuvama Wealth Management Ltd. 0.27 0.04 132 Home First Finance Company India Ltd. 0.27 0.05 133 NBCC (India) Ltd. 0.27 0.04 134 Ipca Laboratories Ltd. 0.27 0.05 135 Bank of India 0.27 0.03 136 Inox Wind Ltd. 0.27 0.04 137 Sundram Fasteners Ltd. 0.26 0.08 138 Ather Energy Ltd. 0.26 0.06 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 55139 Force Motors Ltd. 0.26 0.04 140 Kirloskar Oil Eng Ltd. 0.26 0.06 141 Atul Ltd. 0.26 0.05 142 Indian Energy Exchange Ltd. 0.25 0.04 143 Emami Ltd. 0.25 0.06 144 Piramal Pharma Ltd. 0.25 0.04 145 Indian Railway Catering And Tourism 0.25 0.02 Corporation Ltd. 146 CESC Ltd. 0.25 0.04 147 Tata Elxsi Ltd. 0.25 0.03 148 Craftsman Automation Ltd. 0.25 0.06 149 Astral Ltd. 0.25 0.03 150 eClerx Services Ltd. 0.25 0.06 151 Aptus Value Housing Finance India Ltd. 0.25 0.05 152 Oberoi Realty Ltd. 0.24 0.04 153 Firstsource Solutions Ltd. 0.24 0.05 154 Tata Communications Ltd. 0.24 0.04 155 PG Electroplast Ltd. 0.24 0.04 156 Container Corporation of India Ltd. 0.24 0.03 157 Rail Vikas Nigam Ltd. 0.24 0.03 158 Cyient Ltd. 0.24 0.04 159 Aarti Industries Ltd. 0.24 0.04 160 Oracle Financial Services Software Ltd. 0.24 0.03 161 E.I.D. Parry (India) Ltd. 0.24 0.05 162 Patanjali Foods Ltd. 0.23 0.03 163 Carborundum Universal Ltd. 0.23 0.06 164 Castrol India Ltd. 0.23 0.03 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 56165 Dalmia Bharat Ltd. 0.23 0.04 166 ITC Hotels Ltd. 0.23 0.05 167 HBL Engineering Ltd. 0.23 0.05 168 Five-Star Business Finance Ltd. 0.22 0.05 169 Gujarat State Petronet Ltd. 0.22 0.07 170 Aegis Logistics Ltd. 0.22 0.04 171 Nippon Life India Asset Management Ltd. 0.22 0.04 172 Apollo Tyres Ltd. 0.22 0.03 173 Lloyds Metals And Energy Ltd. 0.22 0.05 174 Granules India Ltd. 0.22 0.05 175 Apar Industries Ltd. 0.22 0.05 176 Anant Raj Ltd. 0.21 0.04 177 Inventurus Knowledge Solutions Ltd. 0.21 0.06 178 KPIT Technologies Ltd. 0.21 0.03 179 Ceat Ltd. 0.21 0.05 180 LIC Housing Finance Ltd. 0.21 0.02 181 Reliance Power Ltd. 0.21 0.09 182 AIA Engineering Ltd. 0.21 0.06 183 Schaeffler India Ltd. 0.21 0.05 184 Exide Industries Ltd. 0.20 0.03 185 Kec International Ltd. 0.20 0.04 186 Zee Entertainment Enterprises Ltd. 0.20 0.03 187 Can Fin Homes Ltd. 0.20 0.05 188 Adani Total Gas Ltd. 0.20 0.04 189 Jubilant Pharmova Ltd. 0.20 0.06 190 Nava Ltd. 0.20 0.05 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 57191 Eris Lifesciences Ltd. 0.20 0.08 192 Kajaria Ceramics Ltd. 0.20 0.05 193 Birlasoft Ltd. 0.20 0.04 194 HFCL Ltd. 0.20 0.04 195 Kalyan Jewellers India Ltd. 0.19 0.02 196 Go Digit General Insurance Ltd. 0.19 0.08 197 Data Patterns (India) Ltd. 0.19 0.04 198 NATCO Pharma Ltd. 0.19 0.04 199 Gujarat Fluorochemicals Ltd. 0.19 0.05 200 Usha Martin Ltd. 0.19 0.06 201 Abbott India Ltd. 0.19 0.06 202 Zensar Technolgies Ltd. 0.19 0.04 203 Maharashtra Scooters Ltd. 0.19 0.15 204 Jaiprakash Power Ventures Ltd. 0.19 0.06 205 Sagility Ltd. 0.19 0.06 206 Garden Reach Shipbuilders & Engineers 0.18 0.03 Ltd. 207 Pfizer Ltd. 0.18 0.05 208 PVR INOX Ltd. 0.18 0.04 209 Jyoti CNC Automation Ltd. 0.18 0.07 210 Gillette India Ltd. 0.18 0.05 211 Berger Paints India Ltd. 0.18 0.04 212 CCL Products (I) Ltd. 0.18 0.06 213 Indiamart Intermesh Ltd. 0.18 0.05 214 CreditAccess Grameen Ltd. 0.18 0.05 215 Intellect Design Arena Ltd. 0.18 0.05 216 Bank of Maharashtra 0.18 0.04 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 58217 Deepak Fertilisers & Petrochemicals Corp. 0.18 0.04 Ltd. 218 Aditya Birla Real Estate Ltd. 0.18 0.06 219 EIH Ltd. 0.17 0.06 220 BEML Ltd. 0.17 0.03 221 Sobha Ltd. 0.17 0.06 222 Syrma SGS Technology Ltd. 0.17 0.05 223 Capri Global Capital Ltd. 0.17 0.05 224 Linde India Ltd. 0.17 0.06 225 Cochin Shipyard Ltd. 0.17 0.02 226 JK Tyre & Industries Ltd. 0.17 0.05 227 Chambal Fertilizers & Chemicals Ltd. 0.17 0.03 228 Onesource Specialty Pharma Ltd. 0.17 0.07 229 Lemon Tree Hotels Ltd. 0.17 0.04 230 Escorts Kubota Ltd. 0.17 0.04 231 V-Guard Industries Ltd. 0.16 0.07 232 Bharti Hexacom Ltd. 0.16 0.06 233 Indraprastha Gas Ltd. 0.16 0.04 234 Godawari Power & Ispat Ltd. 0.16 0.06 235 Titagarh Rail Systems Ltd. 0.16 0.03 236 NCC Ltd. 0.16 0.03 237 Motilal Oswal Financial Services Ltd. 0.16 0.04 238 Ajanta Pharmaceuticals Ltd. 0.16 0.05 239 Zen Technologies Ltd. 0.16 0.05 240 Bharat Dynamics Ltd. 0.16 0.03 241 Mahanagar Gas Ltd. 0.16 0.04 242 Chalet Hotels Ltd. 0.16 0.07 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 59243 Shyam Metalics and Energy Ltd. 0.16 0.05 244 Sonata Software Ltd. 0.15 0.05 245 General Insurance Corporation of India 0.15 0.04 246 Swan Corp Ltd. 0.15 0.06 247 K.P.R. Mill Ltd. 0.15 0.06 248 Aditya Birla Sun Life AMC Ltd. 0.15 0.06 249 CRISIL Ltd. 0.15 0.05 250 Brainbees Solutions Ltd. 0.15 0.06 251 Thermax Ltd. 0.15 0.04 252 Procter & Gamble Hygiene & Health Care 0.15 0.05 Ltd. 253 Cohance Lifesciences Ltd. 0.15 0.08 254 Ramkrishna Forgings Ltd. 0.15 0.05 255 Triveni Turbine Ltd. 0.15 0.06 256 Deepak Nitrite Ltd. 0.15 0.05 257 Tata Technologies Ltd. 0.15 0.03 258 Poly Medicure Ltd. 0.15 0.06 259 Bayer Cropscience Ltd. 0.15 0.07 260 Choice International Ltd. 0.15 0.04 261 Finolex Cables Ltd. 0.14 0.04 262 Rainbow Childrens Medicare Ltd. 0.14 0.06 263 United Breweries Ltd. 0.14 0.05 264 Aditya Birla Lifestyle Brands Ltd. 0.14 0.09 265 Ola Electric Mobility Ltd. 0.14 0.09 266 Aavas Financiers Ltd. 0.14 0.05 267 L&T Technology Services Ltd. 0.14 0.05 268 LT Foods Ltd. 0.14 0.06 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 60269 Bata India Ltd. 0.14 0.05 270 Indian Renewable Energy Development 0.14 0.04 Agency Ltd. 271 Sun TV Network Ltd. 0.14 0.06 272 ACC Ltd. 0.14 0.03 273 Devyani International Ltd. 0.14 0.05 274 AstraZenca Pharma India Ltd. 0.14 0.06 275 Gravita India Ltd. 0.14 0.05 276 Jubilant Ingrevia Ltd. 0.14 0.06 277 Glaxosmithkline Pharmaceuticals Ltd. 0.14 0.04 278 3M India Ltd. 0.13 0.05 279 AWL Agri Business Ltd. 0.13 0.04 280 Sumitomo Chemical India Ltd. 0.13 0.07 281 Techno Electric & Engineering Company 0.13 0.06 Ltd. 282 Whirlpool of India Ltd. 0.13 0.06 283 Sapphire Foods India Ltd. 0.13 0.09 284 Metropolis Healthcare Ltd. 0.13 0.06 285 Balrampur Chini Mills Ltd. 0.13 0.05 286 Netweb Technologies India Ltd. 0.13 0.04 287 Housing & Urban Development Corporation 0.13 0.04 Ltd. 288 Gujarat Mineral Development Corporation 0.13 0.05 Ltd. 289 Afcons Infrastructure Ltd. 0.13 0.05 290 Aadhar Housing Finance Ltd. 0.13 0.06 291 IRCON International Ltd. 0.13 0.04 292 Vardhman Textiles Ltd. 0.13 0.07 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 61293 Hexaware Technologies Ltd. 0.13 0.05 294 PCBL Chemical Ltd. 0.13 0.05 295 Indegene Ltd. 0.13 0.07 296 Finolex Industries Ltd. 0.13 0.06 297 Global Health Ltd. 0.13 0.06 298 Sarda Energy and Minerals Ltd. 0.13 0.07 299 TBO Tek Ltd. 0.12 0.07 300 JM Financial Ltd. 0.12 0.05 301 R R Kabel Ltd. 0.12 0.06 302 NMDC Steel Ltd. 0.12 0.06 303 Minda Corporation Ltd. 0.12 0.07 304 Century Plyboards (India) Ltd. 0.12 0.1 305 Niva Bupa Health Insurance Company Ltd. 0.12 0.06 306 Engineers India Ltd. 0.12 0.04 307 Vijaya Diagnostic Centre Ltd. 0.12 0.06 308 Premier Energies Ltd. 0.12 0.05 309 Jammu & Kashmir Bank Ltd. 0.12 0.05 310 DCM Shriram Ltd. 0.12 0.07 311 Syngene International Ltd. 0.12 0.04 312 Welspun Living Ltd. 0.12 0.05 313 Alembic Pharmaceuticals Ltd. 0.12 0.08 314 H.E.G. Ltd. 0.12 0.04 315 Endurance Technologies Ltd. 0.12 0.06 316 UTI Asset Management Company Ltd. 0.11 0.05 317 DOMS Industries Ltd. 0.11 0.06 318 JSW Infrastructure Ltd. 0.11 0.05 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 62319 NLC India Ltd. 0.11 0.05 320 Emcure Pharmaceuticals Ltd. 0.11 0.11 321 IRB Infrastructure Developers Ltd. 0.11 0.05 322 Chennai Petroleum Corporation Ltd. 0.11 0.04 323 Jindal Saw Ltd. 0.11 0.04 324 Schneider Electric Infrastructure Ltd. 0.11 0.25 325 Bikaji Foods International Ltd. 0.11 0.06 326 BASF India Ltd. 0.11 0.07 327 Olectra Greentech Ltd. 0.11 0.04 328 Tata Investment Corporation Ltd. 0.11 0.04 329 Godfrey Phillips India Ltd. 0.11 0.05 330 NTPC Green Energy Ltd. 0.11 0.04 331 Graphite India Ltd. 0.11 0.04 332 Jupiter Wagons Ltd. 0.11 0.05 333 IFCI Ltd. 0.10 0.05 334 Kirloskar Brothers Ltd. 0.10 0.07 335 Clean Science and Technology Ltd. 0.10 0.06 336 Aditya Birla Fashion and Retail Ltd. 0.10 0.05 337 Honasa Consumer Ltd. 0.10 0.08 338 Concord Biotech Ltd. 0.10 0.07 339 Elecon Engineering Co. Ltd. 0.10 0.06 340 Caplin Point Laboratories Ltd. 0.10 0.06 341 Gujarat Gas Ltd. 0.10 0.06 342 Shipping Corporation of India Ltd. 0.10 0.04 343 Akzo Nobel India Ltd. 0.10 0.07 344 Honeywell Automation India Ltd. 0.10 0.05 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 63345 KSB Ltd. 0.09 0.09 346 Action Construction Equipment Ltd. 0.09 0.06 347 BLS International Services Ltd. 0.09 0.05 348 Reliance Infrastructure Ltd. 0.09 0.25 349 Central Bank of India 0.09 0.05 350 SBFC Finance Ltd. 0.09 0.07 351 Praj Industries Ltd. 0.09 0.05 352 Trident Ltd. 0.09 0.05 353 Dr. Agarwal's Health Care Ltd. 0.09 0.08 354 Leela Palaces Hotels & Resorts Ltd. 0.09 0.07 355 Nuvoco Vistas Corporation Ltd. 0.09 0.07 356 Newgen Software Technologies Ltd. 0.09 0.04 357 Blue Dart Express Ltd. 0.09 0.07 358 Signatureglobal (India) Ltd. 0.09 0.08 359 Jyothy Labs Ltd. 0.08 0.07 360 Mangalore Refinery & Petrochemicals Ltd. 0.08 0.04 361 Happiest Minds Technologies Ltd. 0.08 0.05 362 Aegis Vopak Terminals Ltd. 0.08 0.13 363 International Gemmological Institute 0.08 0.08 (India) Ltd. 364 Triveni Engineering & Industries Ltd. 0.08 0.07 365 Latent View Analytics Ltd. 0.08 0.07 366 Bombay Burmah Trading Corporation Ltd. 0.08 0.06 367 India Cements Ltd. 0.08 0.06 368 IDBI Bank Ltd. 0.08 0.03 369 RITES Ltd. 0.08 0.05 370 Valor Estate Ltd. 0.08 0.11 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 64371 Cera Sanitaryware Ltd 0.07 0.06 372 Railtel Corporation Of India Ltd. 0.07 0.04 373 Vedant Fashions Ltd. 0.07 0.07 374 ITI Ltd. 0.07 0.08 375 Tejas Networks Ltd. 0.07 0.05 376 Transformers And Rectifiers (India) Ltd. 0.07 0.06 377 SJVN Ltd. 0.07 0.04 378 RHI MAGNESITA INDIA LTD. 0.07 0.08 379 Godrej Agrovet Ltd. 0.07 0.05 380 Indian Overseas Bank 0.07 0.05 381 JSW Cement Ltd. 0.07 0.05 382 INOX India Ltd. 0.07 0.09 383 Fertilisers and Chemicals Travancore Ltd. 0.06 0.05 384 Saregama India Ltd 0.06 0.07 385 JBM Auto Ltd. 0.06 0.05 386 Campus Activewear Ltd. 0.06 0.07 387 ACME Solar Holdings Ltd. 0.06 0.06 388 Godrej Industries Ltd. 0.06 0.07 389 Tata Teleservices (Maharashtra) Ltd. 0.06 0.19 390 C.E. Info Systems Ltd. 0.06 0.05 391 Alkyl Amines Chemicals Ltd. 0.06 0.08 392 Maharashtra Seamless Ltd. 0.05 0.06 393 Ventive Hospitality Ltd. 0.05 0.09 394 Alok Industries Ltd. 0.05 0.08 395 Rashtriya Chemicals & Fertilizers Ltd. 0.05 0.04 396 The New India Assurance Company Ltd. 0.05 0.05 Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 65397 UCO Bank 0.04 0.05 398 Blue Jet Healthcare Ltd. 0.04 0.08 399 Akums Drugs and Pharmaceuticals Ltd. 0.03 0.09 400 MMTC Ltd. 0.02 0.13 Index Service Provider NSE Indices Limited (NSE Indices), a subsidiary of NSE Strategic Investment Corporation Limited was set up in May 1998 to provide a variety of indices and index related services and products for the Indian capital markets. NSE Indices provides a broad range of services, products and professional index services. Portfolio concentration norms In accordance with clause 3.4 of Master Circular, the Index shall comply with the following portfolio concentration norms: (a) The Index shall have a minimum of 10 stocks as its constituents. (b) No single stock shall have more than 25% weight in the Index. (c) The weightage of the top three constituents of the Index, cumulatively shall not be more than 65% of the Index. (d) The individual constituent of the Index shall have a trading frequency greater than or equal to 80% and an average impact cost of 1% or less over the previous six months. The Scheme shall monitor compliance with the aforesaid norms by the Index at the end of every calendar quarter. Further, the updated constituents of the Index will be made available on the website of the Fund. E. Principles of incentive structure for market makers (for ETFs) Not Applicable. F. Floors and ceiling within a range of 5% of the intended allocation against each sub class of asset, as per clause 13.6.2 of SEBI master circular for mutual funds dated June 27, 2024 (only for close ended debt schemes) Not Applicable. [This space is left blank intentionally] Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 66G. Other Scheme Specific Disclosures Listing and The Scheme is an open-ended equity Scheme under which Sale and Repurchase will transfer of units be made on a continuous basis and therefore listing on stock exchanges is not envisaged. Units held in Demat Form are freely transferable. Further, the units held in SoA (Statement of Accounts) mode can be transferred in a manner as prescribed by AMFI from time to time. This facility shall be available only through online mode via the transaction portals of our Registrar and Transfer Agent (i.e. CAMS) and the MF Central (as and when enabled), i.e., the transfer of units held in SoA mode shall not be allowed through physical/ paper-based mode or via the stock exchange platforms, MFU, channel partners and EOPs etc. The Stamp duty for transfer of units, if/where applicable, shall be payable by the transferor. Unitholders can refer https://digital.camsonline.com/transfer for more details and can follow the process available on website of our CAMS if intends to transfer their units in scenarios prescribed below: ● Surviving joint unitholder, who wants to add new joint holder(s) in the folio upon demise of one or more joint unitholder(s). ● A nominee of a deceased unitholder, who wants to transfer the units to the legal heirs of the deceased unitholder, post the transmission of units in the name of the nominee. ● A minor unitholder who has turned a major and has changed his/her status from minor to major, wants to add the name of the parent / guardian, sibling, spouse etc. in the folio as joint holder(s). ● Transfer to Siblings, ● Gifting of Units ● Transfer of units to the third party ● Addition / Deletion of the holder. Dematerializatio The Unit holders would have an option to hold the Units in demat form or account n of units statement (non-demat) form. The Applicant intending to hold Units in demat form (Consolidated will be required to have a beneficiary account with a Depository Participant (DP) of Std. Obs. 57) the NSDL/ CDSL and will be required to mention in the application form DP's Name, DP ID No. and Beneficiary Account No. with the DP at the time of purchasing Units. In case unitholders do not provide their Demat Account details, an Account Statement shall be sent to them. Such unitholders will not be able to purchase/redeem the units on the stock exchange. Minimum Target The minimum target amount to be raised during the NFO Period shall be ₹ 10 Crores. amount Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 67(This is the minimum amount required to operate the Scheme and if this is not collected during the NFO period, then all the investors would be refunded the amount invested without any return.) Maximum Not Applicable Amount to be raised (if any) Dividend Policy Not Applicable (IDCW ) Allotment During continuous subscription of the Scheme, all applicants whose monies towards (Detailed purchase of Units have been realized by the Fund will receive a full and firm procedure) allotment of Units, provided also the applications are complete in all respects and are found to be in order. An allotment confirmation specifying the units allotted shall be sent by way of email and/or SMS within 05 Business Days of the receipt of valid application / transaction to the Unit holders registered e-mail address and/ or mobile number. Refer to the Section on Account Statements below for more details on the timelines with regards to dispatch of Account Statements after the Scheme is open for Continuous subscription. Please refer to SAI for details. Refund If the application is rejected, the full amount will be refunded within 5 working days of closure of NFO. If refunded later than 5 working days @ 15% p.a. for a delay period will be paid and charged to the AMC. Who Can Invest The following persons are eligible and may apply for subscription to the Units of the Scheme provided they are not prohibited by any law/ Constitutive documents (This is an governing them: indicative list and you are requested 1. Resident adult individuals either singly or jointly (not exceeding three) or on to consult your an anyone or survivor basis; financial advisor to ascertain 2. Karta of Hindu Undivided Family (HUF); whether the scheme is Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 68suitable to your 3. Minor (as the first and the sole holder only) through a natural guardian (i.e. risk profile) father or mother, as the case may be) or a court appointed legal guardian. There shall not be any joint holding with minor investments. Further, all other requirements for investments by minor and process of transmission shall be followed in line with SEBI Master Circular dated June 27, 2024 read with SEBI Circular dated May 12, 2023 as amended from time to time. (Consolidated Std. Obs. 37) Note : For folios where the units are held on behalf of the minor, the account shall be frozen for operation by the guardian on the day the minor attains majority and no transactions shall be permitted till the requisite documents for changing the status of the account from 'minor' to 'major' are submitted. 4. Proprietorship in the name of Sole Proprietor; 5. Partnership Firms & Limited Liability Partnerships (LLPs); 6. Companies, Bodies Corporate, Public Sector Undertakings, Association of Persons (AOP) or Bodies of Individuals (BOI) and societies registered under the Societies Registration Act, 1860, Co-Operative Societies registered under the Co-Operative Societies Act, 1912; 7. Banks & Financial Institutions; 8. Mutual Funds/ Alternative Investment Funds registered with SEBI; 9. Religious and Charitable Trusts, Wakfs or endowments of private trusts (subject to receipt of necessary approvals as required) and Private trusts authorised to invest in mutual fund schemes under their trust deeds; 10. Non-resident Indians (NRIs)/Persons of Indian Origin residing abroad (PIO)/ Overseas Citizen of India (OCI) on repatriation basis or on non-repatriation basis; 11. Foreign Portfolio Investors (FPI) registered with SEBI in accordance with applicable laws; 12. Army, Air Force, Navy and other paramilitary units and bodies created by such institutions; 13. Scientific and Industrial Research Organizations; 14. Council of Scientific and Industrial Research, India; 15. Multilateral Financial Institutions/ Bilateral Development Corporation Agencies/ Bodies Corporate incorporated outside India with the permission of Government of India/Reserve Bank of India; 16. Provident/ Pension/ Gratuity Fund to the extent they are permitted; Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 6917. Qualified Foreign Investor (QFI); 18. Other Schemes of Zerodha Mutual Fund subject to the conditions and limits prescribed by SEBI (MF) Regulations; 19. Such other category of investors as may be decided by the AMC / Trustee from time to time provided their investment is in conformity with the applicable laws and SEBI (MF) Regulations. The list given above is indicative and the applicable laws, if any, as amended from time to time shall supersede the list. Who cannot 1. Any individual who is a foreign national or any other entity that is not an Indian invest resident under the Foreign Exchange Management Act, 1999 (FEMA Act) except where registered with SEBI as a FPI or otherwise explicitly permitted under FEMA Act/ by RBI/ by any other applicable authority; 2. Overseas Corporate Bodies (OCBs); 3. NRIs residing in Non-Compliant Countries and Territories (NCCTs) as determined by the Financial Action Task Force (FATF); 4. U.S. Persons and Residents of Canada as defined under the applicable laws of U.S. and Canada; 5. Such other persons as may be specified by AMC/ Trustee from time to time. How to Apply Investors can submit the application for purchase and redemption transactions in the and other details schemes of Zerodha Mutual Fund at the Official Points of Acceptance (OPA). (Consolidated Std. Obs. 35) Please refer to the SAI for the details. The Investor may also reach out to the investor support email id support@zerodhafundhouse.com for details/ help in investing. The list of OPA is available on the website of AMC i.e., www.zerodhafundhouse.com Please refer to Page no. 81 for Official Points of Acceptance, Registrar and Transfer Agent (RTA) and Collecting Banker details. As per the directives issued by SEBI, it is mandatory for applicants to mention their bank account numbers in their applications and therefore, investors are requested to fill-up the appropriate box in the application form failing which applications are liable to be rejected. Investors are required to mandatorily provide a valid and active email ID at the time of submitting the application form. The email ID provided will be used for all future communications including, but not limited to, the Statement of Account (SOA), Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 70transaction confirmations, and portfolio updates. In case a valid email ID is not provided, the investor may not receive such communications. Terms and conditions for transactions through email for non-individual investors Non Individual Investors desiring to avail the facility of conducting financial transactions in the Scheme(s) of Zerodha Mutual Fund via email as provided under AMFIʼs Best Practice Guidelines Circular No.135/BP/118 /2024-25 dated 31st January 2025, shall note the following: Terms and conditions for transactions through email: ● The AMC can accept financial transactions from non-individual investors through email, subject to the following: ● The non-individual investor must provide a copy of the board resolution or authority letter, as specified by the AMC, granting authority to designated officials. ● Transactions via emails, scanned copies of signed forms, or electronically executed documents with valid Digital Signature Certificates (DSC) or Aadhaar based e-signatures may be accepted as per the conditions specified in the aforementioned circular. ● Non Individual Investors should be aware of the risks associated with email transactions, including transmission errors and cyber security risks. The AMC/RTA shall not be liable in any manner whatsoever in case the transaction sent or purported to be sent by the investor is not received by the AMC/ RTA due to any reason and hence not processed. ● The non-individual investors must have necessary safeguards to ensure the security of email communications and retain transaction records as per applicable laws/regulations. ● Any addition/deletion of authorized signatories by the non-individual investors shall be done in the manner specified by the AMC. ● Any change in the registered email id/contact details shall be accepted only from the designated officials authorized to notify such changes vide board resolutions/authority letter. Further, such change request shall be submitted through physical request letter (or a scanned copy thereof with wet signature of the designated authorized officials) only. ● No change in /addition to the bank mandate shall be allowed via email. Change in bank details or addition of bank account of the investor shall be permitted only via the prescribed service request form duly signed by the investorʼs authorized signatories with wet signature of the designated authorized officials. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 71● The AMC will adopt security procedures, electronic time stamping mechanisms and audit trails for email transactions, as may be required. ● The AMC may specify additional terms and conditions for email transactions, and investors are advised to refer to the latest guidelines hosted on the AMC's website from time to time. The policy Presently, the AMC does not intend to reissue the repurchased Units. regarding reissue of repurchased However, the Trustee reserves the right to reissue the repurchased Units at a later units, including date after issuing adequate public notices and taking approvals, if any, from SEBI. the maximum extent, the manner of reissue, the entity (the scheme or the AMC) involved in the same. Restrictions, if The Units of the Scheme held in electronic (demat) mode are transferable. The any, on the right Mutual Fund at its sole discretion reserves the right to suspend sale and switching of to freely retain or Units in the Scheme temporarily or indefinitely when any of the following conditions dispose of units exist. However, the suspension of sale of Units either temporarily or indefinitely will being offered. be with the approval of the Trustee. a. When one or more stock exchanges or markets, which provide a basis for valuation for a substantial portion of the assets of the Scheme are closed otherwise than for ordinary holidays. b. When, as a result of political, economic or monetary events or any circumstances outside the control of the Trustee and the AMC, the disposal of the assets of the Scheme are not reasonable, or would not reasonably be practicable without being detrimental to the interests of the Unit holders. c. In the event of breakdown in the means of communication used for the valuation of investments of the Scheme, without which the value of the securities of the Scheme cannot be accurately calculated. d. During periods of extreme volatility of markets, which in the opinion of the AMC are prejudicial to the interests of the Unit holders of the Scheme. e. In case of natural calamities, strikes, riots and bandhs. f. In the event of any force majeure or disaster that affects the normal functioning of the AMC. g. If so directed by SEBI. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 72The AMC/ Trustee reserves the right in its sole discretion to withdraw the facility of Sale option of Units into the Scheme, temporarily or indefinitely, if AMC views that changing the size of the corpus further may prove detrimental to the existing Unit holders of the Scheme. Cut off timing for Subscriptions: subscriptions/ redemptions The following cut-off timings shall be observed by the Mutual Fund in respect of purchase of units of the Scheme and the following NAVs shall be applied for such This is the time purchase: before which your application Cut off timing for Subscriptions: (complete in all respects) should a. In respect of valid applications received upto 03.00 p.m on a Business Day reach the official and funds for the entire amount of subscription/purchase as per the points of application are credited to the bank account of the respective Scheme before acceptance. the cut-off time i.e. available for utilization before the cut-off time – the closing NAV of the day on which the funds are available for utilization shall be applicable. b. In respect of valid applications received after 03.00 p.m on a Business Day and funds for the entire amount of subscription/purchase as per the application are credited to the bank account of the respective Scheme after cut-off time i.e. available for utilization after the cut-off time – the closing NAV of the next Business Day on which the funds are available for utilization shall be applicable. c. Irrespective of the time of the receipt of valid application where funds for the entire amount of subscription/purchase as per the application are credited to the bank account of the respective Scheme before cut-off time of next business day i.e. available for utilization before the cut-off time on any subsequent Business day - the closing NAV of the day of such Business day on which the funds are available for utilization shall be applicable. Redemptions: The following cut-off timings shall be observed by the Mutual Fund in respect of Redemptions of Units: 1. Where the application received upto 03.00 pm – closing NAV of the day of receipt of application; and 2. An application received after 03.00 pm – closing NAV of the next Business Day. Note: In case the application is received on a Non-Business Day, it will be considered as if received on the Next Business Day . Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 73Minimum Minimum amount for purchase: amount for purchase/ ₹ 100 and in multiples of ʻany amountʼ thereafter. redemption Minimum Additional Purchase Amount: ₹ 100 and in multiples of ʻany amountʼ thereafter. Minimum Redemption Amount: The minimum redemption amount shall be ʻany amountʼ or ʻany number of unitsʼ as requested by the investor at the time of redemption. The Redemption would be permitted to the extent of credit balance in the Unit holderʼs account of the Scheme (subject to completion of Lock-in period or release of pledge / lien or other encumbrances). The Redemption request can be made by specifying the rupee amount or by specifying the number of Units to be redeemed. The AMC/ Trustee reserves the right to change/ modify the terms of minimum purchase/redemption amount provision offered under the Scheme of the Fund. Accounts The AMC shall send an allotment confirmation specifying the units allotted by way of Statements email and/or SMS within 5 working days of receipt of valid application/transaction to (Standard the Unit holders registered e-mail address and/ or mobile number (whether units are Observation 18) held in demat mode or in account statement form). (Consolidated Std. Obs. 60) A Consolidated Account Statement (CAS) detailing all the transactions across all mutual funds (including transaction charges paid to the distributor) and holding at the end of the month shall be sent to the Unit holders in whose folio(s) transaction(s) have taken place during the month via electronic mode (e-CAS) by the twelfth (12th) day from the month end and to investors that have opted for delivery via physical mode by the fifteenth (15th) day from the month end. Half-yearly CAS shall be issued at the end of every six months (i.e. September/ March) to investors that have opted for e-CAS on or before the eighteenth (18th) day of April and October and to investors that have opted for delivery via physical mode by the twenty first (21st) day of April and October. For further details, refer to SAI. Dividend/ IDCW Not Applicable Redemption The redemption or repurchase proceeds shall be dispatched to the unitholders within three working days from the date of redemption or repurchase. For list of exceptional circumstances refer para 14.1.3 of SEBI Master Circular for Mutual Funds dated June 27, 2024. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 74The redemption proceeds will be credited to the bank account of the Unitholder, as per the bank account details recorded with the DP. Units will be redeemed on First In First Out (FIFO) basis. Redemption requests may not be processed if KYC compliant status is not updated in the folio. Bank Mandate As per the directives issued by SEBI, it is mandatory for applicants to mention their (Standard bank account numbers in their applications and therefore, investors are requested to Observation 19) fill-up the appropriate box in the application form failing which applications are (Consolidated liable to be rejected. Std. Obs. 61) Multiple Bank Account Registration The AMC/ Mutual Fund provides a facility to the investors to register multiple bank accounts (currently upto 5 for Individuals and 10 for Non - Individuals) for receiving redemption by providing necessary details. Investors must specify any one account as the "Default Bank Account". The investor, may however, specify any other registered bank account for credit of redemption proceeds at the time of requesting for redemption. Change in Bank Account Investors may reach out to support@zerodhafundhouse.com for requesting a change in their Bank Account for folios held in Statement of Account (SOA) mode. The facility for change in Bank Account for the Units held in demat mode is available. The investors are requested to reach out to the respective Depository Participant. Delay in payment The AMC shall be liable to pay interest to the unitholders at rate as specified vide of redemption / clause 14.2 of SEBI Master Circular for Mutual Funds dated June 27, 2024 by SEBI for repurchase the period of such delay. proceeds/ dividend Unclaimed Please refer to SAI for details. Redemption (Consolidated Std. Obs. 52) Disclosure w.r.t Process for Investments made in the name of Minor through a Guardian investment by minors Payment for investment from the bank account of the minor or from a joint account of the minor with the guardian only, else the transaction is liable to get rejected. Unit holders are requested to review the Bank Account registered in the folio and ensure that the registered Bank Mandate is in favour of minor or joint with registered guardian in folio. If the registered Bank Account is not in favour of minor or not joint with registered guardian, unit holders will be required to submit the change of bank mandate, where minor is also a bank account holder (either single or joint with registered guardian), before initiation any redemption Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 75transaction in the folio, else the transaction is liable to get rejected. For systematic transactions in a minorʼs folio, AMC will register standing instructions till the date of the minor attaining majority, though the instructions may be for a period beyond that date. Upon the minor attaining the status of major, the minor in whose name the investment was made, shall be required to provide all the KYC details and updated bank account details. No further transactions shall be allowed till the status of the minor is changed to major. Any other Minimum balance to be maintained and consequences of non- maintenance. disclosure in (Consolidated Std. Obs. 36) terms of Consolidated Currently, there is no minimum balance requirement. Checklist on Standard Risk-o-meter (Consolidated Std. Obs. 38) Observations The risk-o-meter of the Scheme shall be evaluated on a monthly basis and shall be disclosed along with portfolio disclosure on the AMC website and on AMFI website within 10 days from the close of each month. The risk level of the Scheme as on March 31 of every year, along with the number of times the risk level has changed over the year, shall be disclosed on the AMC website and AMFI website. The scheme wise changes in Risk-o-meter shall be disclosed in scheme wise Annual Reports and Abridged summary. Scheme Summary Document (Consolidated Std. Obs. 38) The AMC will provide on its website a standalone scheme document for all the Schemes which contains all the details of the Scheme viz. Scheme features, Fund Manager details, investment details, investment objective, expense ratios, portfolio details, etc. III. Other Details A. In case of Fund of Funds Scheme, Details of Benchmark, Investment Objective, Investment Strategy, TER, AUM, Year wise performance, Top 10 Holding/ link to Top 10 holding of the underlying fund should be provided Not Applicable. B. Periodic Disclosures such as Half yearly disclosures, half yearly results, annual report a. Annual Report Scheme Annual report in the format prescribed by SEBI, will be hosted on the website of the Fund viz. www.zerodhafundhouse.com and on the website of Association of Mutual Funds in India (AMFI) viz. www.amfiindia.com as soon as may be but not later than four months from the Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 76date of closure of the relevant accounts year (i.e. 31st March each year). Mutual Fund / AMC will publish an advertisement every year, in the all India edition of at least two daily newspapers, one each in English and Hindi, disclosing the hosting of the Scheme wise Annual Report on the website of the Fund and on the website of Association of Mutual Funds in India (AMFI). Mutual Fund / AMC will email the Scheme Annual Report or Abridged Summary thereof to the unitholders registered email address with the Mutual Fund. Mutual Fund / AMC will provide a physical copy of the abridged summary of the Annual Report, without charging any cost, on specific request received from a unitholder through any mode. A physical copy of the scheme wise annual report shall be made available for inspection to the investors at the registered office of the AMC. A link of the scheme annual report or abridged summary thereof shall be displayed prominently on the website of the Fund and shall also be displayed on the website of Association of Mutual Funds in India (AMFI). b. Half Yearly Results The Mutual Fund shall host half yearly disclosures of the Schemeʼsʼ unaudited financial results in the prescribed format on its website viz. www.zerodhafundhouse.com within one month from the close of each half year i.e. on 31st March and on 30th September and shall publish an advertisement in this regard in at least one English daily newspaper having nationwide circulation and in a newspaper having wide circulation published in the language of the region where the Head Office of the Mutual Fund is situated. c. Half Yearly Portfolio Statement The Mutual Fund/ AMC will disclose the portfolio (along with ISIN) of the Scheme, including Segregated Portfolio, if any, in the prescribed format, as on the last day of half-year i.e. March 31 and September 30, on its website viz. www.zerodhafundhouse.com and on the website of Association of Mutual Funds in India (AMFI) viz. www.amfiindia.com within 10 days from the close of each half-year respectively. The Mutual Fund / AMC will send via mail, to the registered email address of the unitholders, the half-yearly statement of scheme portfolio within 10 days from the close of each half-year respectively. Mutual Fund / AMC will publish an advertisement every half-year in an all India edition of at least two daily newspapers, one each in English and Hindi, disclosing the hosting of the half-yearly statement of the Scheme portfolio on its website and on the website of Association of Mutual Funds in India (AMFI). Mutual Fund / AMC will provide a physical copy of the statement of its Scheme portfolio, without charging any cost, on specific request received from a unitholder. d. Disclosure of Risk-o-meter (Consolidated Std. Obs. 38) The risk-o-meter of the Scheme shall be evaluated on a monthly basis and shall be disclosed along with portfolio disclosure on the AMC website and on AMFI website within 10 days from the close of each month. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 77Notice about changes in Scheme's Risk-o-meter, if any, shall be issued. The product labeling assigned during the NFO is based on internal assessment of the scheme characteristics and the same may vary post NFO when the actual investments are made. For latest Risk-o-meter of the Scheme and the Benchmark, investors may refer to the monthly portfolios disclosed on the website of the Fund viz. www.zerodhafundhouse.com . The risk level of the Scheme as on March 31 of every year, along with the number of times the risk level has changed over the year, shall be disclosed on the AMC website and AMFI website. The scheme wise changes in Risk-o-meter shall be disclosed in scheme wise Annual Reports and Abridged summary. C. Transparency/NAV Disclosure (Consolidated Std. Obs. 41) The NAV will be calculated by the AMC for each Business Day. The first NAV shall be calculated and declared within 05 business days from the date of allotment. As mandated by SEBI, the NAV shall be disclosed in the following manner: (i) Displayed on the website of Mutual Fund ( www.zerodhafundhouse.com ) (ii) Displayed on the website of Association of Mutual Funds in India (AMFI) ( w ww.amfiindia.com ) (iii) Any other manner as may be mandated by SEBI from time to time Mutual Fund/ AMC will provide facility of sending latest NAVs to unitholders through SMS, upon receiving specific requests. AMC shall update NAV on the website of the Fund and Association of Mutual Funds in India (AMFI) by 11.00 p.m. every Business Day. In case of any delay in uploading on AMFI website, the reason for such delay will be explained to AMFI in writing. If the NAVs are not available before commencement of business hours on the following day due to any reason, Mutual Fund shall issue a press release providing reasons and explaining when the Mutual Fund would be able to publish the NAVs. The AMC will make available the Annual Report of the Scheme within four months of the end of the financial year. D. Transaction charges and stamp duty Transaction Charges As the scheme is offering only the Direct Plan, no transaction charges will be levied or deducted. Please refer to SAI for details. Stamp Duty Pursuant to Notification No. S.O. 1226(E) and G.S.R. 226(E) dated March 30, 2020 issued by Department of Revenue, Ministry of Finance, Government of India, read with Part I of Chapter IV of Notification dated February 21, 2019 issued by Legislative Department, Ministry of Law and Justice, Government of India on the Finance Act, 2019, stamp duty @0.005% of the transaction value would be levied on applicable mutual fund transactions. Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 78Accordingly, pursuant to levy of stamp duty, the number of units allotted on purchase transactions to the unitholders would be reduced to that extent. Please refer to SAI for details. E. Associate Transactions Please refer to SAI for details. F. Taxation For details on taxation please refer to the clause on Taxation in the SAI apart from the following: This information is provided for general information only and is based on the prevailing tax laws, as applicable in case of this Scheme. However, in view of the individual nature of the implications, each investor is advised to consult his or her own tax advisors/ authorized dealers with respect to the specific amount of tax and other implications arising out of his or her participation in the schemes. Resident Non-Resident Mutual Fund Investors (other than FII) Tax on dividend NA NA NIL@ Capital Gain* Long-term Capital Gain (Held for a period of 12.5% 12.5% NIL@ more than 12 months)* Short Term Capital Gains (Held for a 20% 20% NIL@ period of 12 months or less)* @ The levy of tax on distributed income payable by mutual funds has been abolished w.e.f. April 1, 2020 and instead tax on income from mutual fund units in the hands of the unit holders at their applicable rates has been adopted. NA The Scheme does not have a dividend policy, hence not applicable * Surcharge and Health & Education Cess to be levied: The above tax rates are applicable if mutual fund units are held as capital assets Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 79If taxpayer (Individual/HUF/AOP/BOI/AJP) opts for Old Tax Regime, then Surcharge to be levied on basic tax at: • 37% where specified income exceeds Rs.5 crore; • 25% where specified income exceeds Rs.2 crore but does not exceed Rs.5 crore; • 15% where total income exceeds Rs.1 crore but does not exceed Rs.2 crore; and • 10% where total income exceeds Rs.50 lakhs but does not exceed Rs.1 crore. If the taxpayer (Individual/HUF/AOP/BOI/AJP) pays tax as per default New Tax Regime u/s. 115BAC(1A), then the maximum rate of Surcharge will be 25% where income exceeds Rs.2 crore. In case of an AOP consisting of only companies as its members, the rate of surcharge shall not exceed 15%. Surcharge for companies to be levied on basic tax: • Domestic Company: 12% where income exceeds Rs.10 crore and 7% where income exceeds Rs.1 crore but less than Rs.10 crore. If a domestic company opts for concessional tax regime u/s. 115BAA/115BAB: then flat rate of 10% on basic tax • Non-resident Company: 5% where income exceeds Rs.10 crore and 2% where income exceeds Rs.1 crore but less than Rs.10 crore Enhanced surcharge of 25% or 37%, as the case may be, will not apply in case of income by way of dividend or capital gains on securities covered under Section 111A (STCG on EOF), Section 112 (LTCG on non-EOF acquired up to March 31, 2023 and LTCG on non-EOF acquired from April 1, 2023 where equity exposure in such non-EOF > 35%), Section 112A (LTCG on EOF) & Section 115AD (tax on income earned by FIIs). Health & Education Cess @ 4% is applicable on aggregate of basic tax & surcharge. Please note that surcharge and cess shall not be applied on basic tax while deducting TDS, if any, on income of resident investors only. 1. Equity Oriented Funds will also attract Securities Transaction Tax at applicable rates. 2. As per the provisions of section 196A which is specifically applicable in case of non-resident unitholders, a withholding tax rate of 20% (plus applicable surcharge and cess) on any income in respect of units of a Mutual Fund credited/ paid to non-resident unitholders shall apply. The Finance Act, 2023 inserted a proviso to section 196A(1) of the Act to grant relevant tax treaty benefits with effect from 1 April 2023 at the time of withholding tax on income with respect to securities of non-resident unitholders, subject to furnishing of tax residency certificate and such other documents as may be required. As per the provisions of section 196D of the Act which is specifically applicable in case of FPI/FII, the withholding tax rate of 20% (plus applicable surcharge and cess) on any income in respect of securities referred to in section 115AD(1)(a) credited / paid to FII shall apply. The Finance Act, 2021 inserted a proviso to section 196D(1) of the Act to grant relevant tax treaty benefits with effect from 1 April 2021 at the time of withholding tax on income with respect to securities of FPIs, subject to furnishing of tax residency certificate and such other documents as may be required. As Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 80per section 196D(2) of the Act, no TDS shall be made in respect of income by way of capital gain arising from the transfer of securities referred to in section 115AD of the Act. 3. The Finance Act , 2022 provides that in case of domestic company whose income is chargeable to tax under section 115BA, the rate of income-tax shall be 25% if its total turnover or gross receipts in the financial year 2022-23 does not exceed ₹ 400 crores. 4. The corporate tax rates for domestic companies (not claiming specified incentives and deductions) at the rate of 22% under section 115BAA and domestic manufacturing companies (not claiming specified incentives and deductions) set-up and registered on or after 1 October 2019 at the rate of 15% under section 115BAB. The tax computed in case of domestic companies whose income is chargeable to tax under section 115BAA or section 115BAB shall be increased by a surcharge at the rate of 10%. 5. Short term/ long term capital gain tax will be deducted at the time of redemption of units in case of NRI investors only. However, as per section 196A of the Act the withholding tax of 20% (plus applicable surcharge and cess) is applicable on any income in respect of units of mutual fund in case of non-residents. Hence, based on language provided in said section, it seems that apart from any income distributed to NRI, withholding tax at 20% may be applicable on capital gains notwithstanding that such capital gains are taxable at a rate lower than 20%. 6. Section 112A provides that long term capital gains arising from transfer of a long term capital asset being a unit of an equity oriented fund shall be taxed at 10% or 12.50% as the case may be (without indexation and foreign currency fluctuation benefit) of such capital gains exceeding one lakh twenty five thousand rupees. 7. The concessional rate of or 12.50% on long term capital gains arising from transfer of a long term capital asset being a unit of an equity oriented fund shall be available only if STT has been paid on transfer in case of units of equity oriented mutual funds and without giving effect to first and second proviso to section 48 i.e. without taking benefit of foreign currency fluctuation and indexation benefit. Similarly, the concessional rate of 20% on short term capital gains arising from transfer of a short term capital asset being a unit of an equity oriented fund shall be available only if STT has been paid on transfer in case of units of equity oriented mutual funds. 8. Section 206AA of the Income-tax Act, 1961 mandates that if a person receiving income (deductee) fails to furnish a valid and operative PAN to the deductor, tax shall be deducted at the higher of the rate specified under the relevant provisions of the Act, the rate(s) in force, or 20%. A PAN is considered operative only if it is linked with a valid Aadhaar number. However, this provision does not apply to certain non-residents (other than companies) and foreign companies, provided they furnish prescribed documents such as a Tax Residency Certificate and contact details as required. G. Rights of Unitholders Please refer to SAI for details. H. List of official points of acceptance: Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 81Zerodha Fund House is focused on delivering a completely online experience. Accordingly, the Official Point of Acceptance (OPAs) will be online/ electronic mode only, unless specifically specified under the SEBI (MF) Regulations. The investors can undertake any transaction(s), including purchase/redemption and avail of any service(s) from time to time through the online/electronic modes via various sources like: ➔ Direct point of online contact for the AMC, such as the website, mobile application, WhatsApp, or any other online mode of communication by enabling transactions directly or in directly (by redirecting to any other relevant partner platform). ➔ Website/ Mobile App of MFU and MF Central - https://www.mfuindia.com; https://www.mfcentral.com/ ➔ Website/ Mobile App of various aggregator platforms/ channel partners/ business partners/ investment advisers/ execution only platform with whom AMC has entered or may enter into specific arrangements. ➔ CAMS - https://www.camsonline.com/ ➔ Transactions through ONDC Network Participants. The investors can also submit the application by placing the order with the members (stock brokers) of stock exchanges or RIAs through the stock exchange infrastructure (i.e., BSE StAR MF/ NMF/ MFSS). Please refer to the AMC website, viz. www.zerodhafundhouse.com for the list of Official Points of Acceptance I. Penalties, Pending Litigation Or Proceedings, Findings Of Inspections Or Investigations For Which Action May Have Been Taken Or Is In The Process Of Being Taken By Any Regulatory Authority (Standard Observation 20) (Consolidated Std. Obs. 48) a. AMCs are required to disclose penalties, pending litigation etc. for the last 5 financial years and wherever the amount of penalty is more than 5 lakhs. Not Applicable Refer to AMC/Fund Website viz. https://www.zerodhafundhouse.com/resources/disclosures/ for details of penalties, pending litigation, and action taken by SEBI and other regulatory and Govt. Agencies, updated on a continuous basis. Any amendments / replacement / re-enactment of SEBI (MF) Regulations subsequent to the date of the Scheme Information Document shall prevail over those specified in this Scheme Information Document. The Scheme under this Scheme Information Document was approved by the Board of Directors of Zerodha Trustee Private Limited (Trustees to Zerodha Mutual Fund) on February 05, 2026. The Trustees have ensured that the scheme approved is a new product offered by Zerodha Mutual Fund and is not a Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 82minor modification to the existing scheme/fund/product. (Standard Observation 25) (Consolidated Std. Obs. 65) Notwithstanding anything contained in this Scheme Information Document, the provisions of the SEBI (MF) Regulations, guidelines and circulars issued by SEBI from time to time will be applicable. (Standard Observation 22) (Consolidated Std. Obs. 63) For and on behalf of Zerodha Asset Management Private Limited Sd/- (Vishal Jain) Chief Executive Officer ceo@zerodhafundhouse.com Date: February 09, 2026 Place: Bengaluru [This space is left intentionally blank] Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 83List of official points of acceptance: Zerodha Fund House is focused on delivering a completely online experience. Accordingly, the Official Point of Acceptance (OPAs) will be online/ electronic mode only, unless specifically specified under the SEBI (MF) Regulations. The investors can undertake any transaction(s), including purchase/redemption and avail of any service(s) from time to time through the online/electronic modes via various sources like: ➔ Direct point of online contact for the AMC, such as the website, mobile application, WhatsApp, or any other online mode of communication by enabling transactions directly or indirectly (by redirecting to any other relevant partner platform). ➔ Website/ Mobile App of MFU and MF Central - https://www.mfuindia.com ; https://www.mfcentral.com/ ➔ Website/ Mobile App of various aggregator platforms/ channel partners/ business partners/ investment advisers/ execution only platform with whom AMC has entered or may enter into specific arrangements. ➔ CAMS - https://www.camsonline.com/ ➔ Transactions through ONDC Network Participants The investors can also submit the application by placing the order with the members (stock brokers) of stock exchanges or RIAs through the stock exchange infrastructure (i.e., BSE StAR MF/ NMF/ MFSS). [This space is left intentionally blank] Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 84Registrar and Transfer Agent Collecting Bankers Computer Age Management Services Limited (CAMS) YES Bank Limited SEBI Registration No. INR000002813 SEBI Registration No. INBI00000935 Rayala Tower-1, 158 Anna Salai, Kasturba Road, Bangalore - 560 001 Chennai - 600 002 HDFC Bank Limited SEBI Registration No. INBI00000063 Richmond Road, Bangalore - 560 025 ICICI Bank Ltd. SEBI Registration Number INBI00000004 Richmond Town, Bengaluru - 560025 Axis Bank Ltd. SEBI Registration Number INBI00000017 Jayanagar, Bengaluru - 560041 State Bank of India SEBI Registration Number INBI00000038 KORMANGALA,BENGALURU- 560095 Kotak Mahindra Bank Ltd. SEBI Registration Number INBI00000927 Nariman Point, Mumbai- 400021 [This space is left intentionally blank] Draft SID - Zerodha Nifty MidSmallcap400 50:50 Index Fund 85

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