Debenture trustees (DTs) may engage in activities regulated by other financial sector regulators or unregulated fee-based, non- fund-based financial services, provided these are conducted through separate business units (SBUs) on an arm’s-length basis. The circular mandates segregation of staff, records, grievance redressal mechanisms, and disclosure of non-SEBI activities to stakeholders, ensuring transparency and risk awareness. DTs regulated by the Reserve Bank of India must also comply via SBUs.