We, at Raghunandan Capital Pvt Ltd, and / or Raghunandan Industries Pvt Ltd and / or its affiliates recognize the importance of protecting your personal and financial information. We assure that the information parted to us will be kept in strict confidentiality . We will use the information only to help us to service your account, to improve our services to you, to provide you with products you have requested, and to inform you about additional products or services that may be of interest to you. We do not sell your personal information to third parties.

However, RCPL/RIPL  site contains links to and from other Web sites. RCPL/RIPL is not responsible for the privacy practices or the content of such Web sites

Raghunandan Capital Pvt Ltd and / or Raghunandan Industries Pvt Ltd or its affiliates, officers, directors, and employees may from time to time, have positions/holdings in securities/contracts mentioned herein & or derivatives/underlying thereof or be engaged in any other transaction involving such investments / securities and earn brokerage or other compensation or act as advisor or lender / borrower to such company (ies) or have other potential conflict of interest with respect to any recommendation and related information and opinions. Without limiting any of the foregoing, in no event shall Raghunandan Capital Pvt Ltd and / or Raghunandan Industries Pvt Ltd or any of its affiliates or any third party involved in, or related to, computing or compiling the information have any liability for any damages of any kind.

This document contains important information regarding the terms and conditions which apply to your account with Raghunandan Capital Private Limited being the Member of National Stock Exchange of India Ltd., (NSE) having SEBI Registration No. INZ000307234 in Capital Market, Derivatives and Currency Derivatives Segment, Member of Bombay Stock Exchange Ltd. (BSE) having SEBI Registration No. INZ000307234 in Capital Market and Derivatives Segment, Member of Metropolitan Stock Exchange of India Ltd. (MSEI) having SEBI Registration No. INZ000307234 in Currency Derivatives Segment, Member of CDSL having SEBI Registration No. SEBI Registration No. IN-DP-213-2016.

Your access to and use of your account is subject to your compliance with all the terms and conditions set forth herein. PLEASE READ THIS DOCUMENT CAREFULLY and retain it for future reference.

The website is owned, operated and maintained by Raghunandan Capital Private Limited hereinafter referred to as “RCPL”, being a company duly incorporated under the Companies Act,1956 and having its registered office at bhaskar lane , jayendra ganj , Gwalior (M.P.) and corporate office at 26/257B , Sultanganj , Near ashish palace , Agra (U.P.)

Please note that the information contained herein is subject to change without notice

I. Registration for use of the Facilities and Services 

(a) Any person visiting the Web Site may access and use the Facilities by establishing an online persona with a unique ‘Client ID’ and ‘Password’, in the manner as indicated on the Web-Site. “Facilities” shall mean and include any information, materials, documents, chat-room facilities, downloads (software or otherwise), data, stock market quotation ticker tape facilities, and all other information and utilities contained or accessible on or through the Web Site as may be provided on the Web Site from time to time, [other than any information directly required in relation to the Services].

(b) Only persons who enter into an agreement with the “RCPL” and who have been provided with a unique Trading code and Password for trading by the “RCPL” in the manner as indicated on the Web-Site shall be entitled to avail the Services provided by the “RCPL”.

(c) The Terms shall be deemed to form part of the “RCPL”-Constituent Agreement and shall be deemed to be incorporated therein to the same extent as if these provisions had been set forth in full therein. The Constituent’s entitlement to avail the Services or any part thereof shall be subject to compliance with all the terms and conditions set forth herein.

II CONDITIONS OF USE OF THE SERVICES 

II.i Subject Matter of the Services :

The Services offered by the “RCPL” include the sale and purchase of dematerialised securities trading (in e-trading account on the internet and also in off-line trading.

II.ii Order Entry 

(a) The Constituent shall be entitled to place an order for the sale or purchase of any Admitted Security through e-mail, writing, telephonic placement by the Constituent or his duly authorised representatives whose particulars has been provided by the Constituent to the “RCPL” and on receipt of such instructions those orders shall be forwarded for the execution.

(b) All orders entered by Constituent, either electronically or otherwise as detailed above, are based upon their investment decisions and their sole responsibility and will not hold, nor seek to hold the “RCPL” or any of its officers, directors, employees, agents, subsidiaries or affiliates, liable for any trading losses or other losses incurred by Constituent, including in the event that any order is placed by the Constituent on the basis of the Facilities or any information (including any investment information, advice, research reports, or any other information) that may be made available on the Web-Site.

(c) The “RCPL” shall be deemed to not have received any order whether electronically transmitted or otherwise until it has confirmed the receipt of such order as mentioned in sub-clause II.ii (a).

(d) The Constituent agrees that placing an order with the “RCPL”, either electronically or otherwise, does not guarantee execution of the order, regardless of the confirmation by the “RCPL” of the receipt of the order and/or its execution and the “RCPL” shall not be liable for any losses, damage or claims on account of the non-execution of any order placed.

(e) The Constituent hereby accepts all responsibility for knowing the status of all corporate benefits like rights and bonus issues, dividends and stock splits of shares he/she/it intends to trade in or held in his/her/its account. The Constituent further accepts all responsibility for knowing the correct ISIN numbers of the shares in his/her/its account and the eligibility of the shares to meet share pay in obligations to the NSE/BSE whether received by way of purchases, rights, bonuses, stock splits, off market transfers or otherwise.

(f) Prior to placing an order in connection with the sale/purchase or transfer of any securities in which Constituent requires any form of regulatory or other permission, the Constituent must advise the “RCPL” of the status of the securities and furnish necessary documents including opinions of legal counsel prior to the execution of the order. The Constituent acknowledges and accepts that delays may occur in relation to the processing of such orders, despite the necessary documents being furnished in a timely manner. The “RCPL” may at its sole discretion refuse to execute any such order till it is satisfied of the legality of the transaction. The Constituent is responsible for all costs associated with compliance or failure to comply with all the regulatory requirements and hereby agrees to fully indemnify the “RCPL” from any costs, losses, claims or other liability arising on account of such orders.

II.iii Order Execution 

a)The order placed during the trading hours of the NSE/BSE/MCX-SX/USE shall be routed to and executed on the market system. However, in the event that the order is placed at any other time, the order shall be routed to and executed during the next succeeding trading session of the NSE/BSE/MCX-Sx/USE.

(b) The Constituent agrees and appoints the “RCPL” as its agent to take all necessary measures to complete the transactions and hereby authorises the “RCPL” to make any and all advances and expend monies as may be required.

(c) The Constituent acknowledges that whilst orders are normally routed through the market systems almost simultaneously with the placing of the order, the Constituent is aware that the “RCPL” has provided on the Web-Site a facility for reconfirmation of orders which are larger than those specified by the “RCPL”’s risk management policy and is also aware that the “RCPL” has the discretion to reject the execution of such orders based on such risk management policy. The RCPL shall not be liable for any delay or cancellation of any order due to the exercise of the “RCPL”’s discretion under such policy.

(d) The Constituent acknowledges and accepts that the “RCPL” has the sole discretion to reject or cancel any order that may be placed by the Constituent for any reason whatsoever, including for any breach of the Margin requirements as stipulated hereunder in Paragraph II.vi and the “RCPL” shall not be liable for any losses, damage or claims on account of such rejection or cancellation as the case may be.

(e) The Constituent acknowledges and accepts that the NSE/BSE may reject or cancel any trade suo moto without ascribing any reasons therefore and the “RCPL” shall not be liable for any losses, damage or claims on account of such rejection or cancellation as the case may be.

(f) The Constituent further acknowledges and accepts that it will receive the price at which the order was actually executed in the marketplace, which may be different from the price at which the security was traded when the order was entered into the “RCPL”’s system.

(g) The Constituent hereby agrees that “RCPL” shall not be responsible or liable for the execution of any order that may have been placed by the Constituent or any unauthorised use of the Constituent’s Trading Password by any person.

(h) The cancellations or modifications of orders placed is not guaranteed. Cancellation of orders is possible only if the original order remains pending at the NSE/BSE. The cancellation or modification of an order shall be deemed not to have been executed unless a confirmation to such effect is received from the “RCPL”. The Constituent agrees that the “RCPL” shall not be liable for any losses, damage or claims on account of the non-execution or delayed execution of an order of cancellation or modification. Unless otherwise specified by the “RCPL”, any order not executed at the end of the relevant NSE/BSE trading day shall stand cancelled. To remove any doubt, it is hereby clarified that an order placed prior to or during the trading day at the NSE/BSE, shall not remain valid for execution at any subsequent trading day at the NSE/BSE/MCX-Sx/USE.

(i) The Constituent also accepts responsibility for knowing the trading and settlement cycles of the NSE/BSE and the settlements pay in/pay out dates for funds and securities and in the event any trades or transactions are reported late to the RCPL on account of any problems at the Exchange or for whatever reason, the Constituent in turn will be subject to late reporting of transactions.

(j) Any errors reported to the Constituent for any reason whatsoever will stand subsequently corrected to reflect the transaction that was effected in the market and the Constituent agrees that the “RCPL” shall not be liable for any damage, loss or claim in account of such error or correction thereof.

II.iv Purchase of the Admitted Securities 

(a) Prior to placing any order for the purchase of any Admitted Security, the Constituent shall ensure that sufficient cash credit balance is available in its account with the “RCPL”. The Constituent is responsible for all of their orders, including any orders, which exceed the available cash, credit balances available to its account and are executed by the “RCPL”, inadvertently or otherwise.

(b) Any order accepted and executed, inadvertently or otherwise, without sufficient cash credit balance will be subject to cancellation or liquidation at the “RCPL”’s discretion, unless the Constituent immediately, upon demand by the “RCPL”, makes good the shortfall in the amount as indicated by the “RCPL.

(c) The date for payment in the case of purchase of securities by the Constituent will be viewed on the day to day basis by the “RCPL” and the same shall be intimated by the “RCPL” to the Constituent either telephonically or otherwise and the Constituent shall make up the deficiency of balance and bring it to cash credit with the reasonable margin to withstand his future transactions within the ‘margin’ limit provided herein after on the date intimated by the “RCPL” to the Constituent for the same (the “Intimated Date”) and which may be a date which is at least [two] working days in advance of the pay in date of the NSE/BSE. In the case where the payment is not made by the Intimated Date, the securities purchased by the “RCPL” on behalf of the Constituent shall be liable to be sold without any further reference to the Constituent and any loss or damage as a result of such sale would be borne solely by the Constituent.

II.v Sale of the Admitted Securities 

(a) Prior to placing any order for the sale of any Admitted Security, the Constituent shall ensure that the concerned security is available in sufficient quantity in its/his/her account with the “RCPL”. The Constituent is responsible for all of their orders, including any orders, which exceed the available quantity of the relevant security and are executed by the “RCPL”, inadvertently or otherwise.

(b) The Constituent agrees and hereby authorises the “RCPL” to block as sold the relevant securities, as standing to its/his/her account, against its/his/her order to sell securities. If its/his/her order gets executed either fully or partially then the securities to the extent sold, would be unblocked on the trade date and the transaction would be effected. The Constituent agrees that it/he/she shall not withdraw/pledge or otherwise use or attempt to withdraw/pledge or otherwise use, the blocked securities. The Constituent hereby authorises the “RCPL” to dishonour any orders issued against the blocked security.

(c) The Constituent acknowledges and agrees that the proceeds of the sale will not be credited to the cash credit balance account of the Constituent until the securities have been delivered to the NSE/BSE/clearing house and pay out is received from the NSE/BSE/clearing House. The proceeds of all sales will be credited, to the cash credit balances account of the Constituent as maintained by the “RCPL”, directly after settlement date.

(d) If the securities are not received on or before the settlement date or securities received are not in deliverable state or due to any other reason whatsoever, the Constituent is not able to deliver securities, the securities will be auctioned or closed out as per the rules of the NSE/BSE. Consequently, the Constituent will be responsible for any resulting losses and all associated costs including any penalty levied by the NSE/BSE/MCX-Sx/USE.

II.vi Margins 

(a) The Constituent shall maintain such quantity of securities and such amount of cash credit balances (hereinafter referred to as the “Margin”) as required by the applicable statutes, rules, regulations, procedures or as deemed necessary or advisable by the “RCPL”, provided that the Margin shall not at any time be less than [20%] of the price of the Admitted Securities proposed to be purchased or sold. The Constituent agrees that no interest shall be payable on the Margin as maintained with the “RCPL”. The Constituent shall be permitted to trade upto a predetermined number of times of the Margin and the quantum of such multiple shall be determined at the sole discretion of the “RCPL”.

(b) The margin requirement and squaring up process for offline and online trading is different, the margin in online account will not be considered in the offline account and vice-versa unless specifically directed by Constituent. The accounting process for both accounts is different and is independent of each other.

(c) In case there is any change in policy relating to Risk Management pertaining to margin requirement and squaring up process the same would be reflected to the user and at the corporate office and terminals of the “RCPL” and the onus is on the Constituent to keep check, understand, and agree with the Risk Management policy pertaining to margin requirement and squaring up process from time to time.

(d) The Constituent shall also remain in touch with the “RCPL” to keep a regular check on his account and margin requirements, for maintaining sufficient margin with the “RCPL” to undertake any transaction in his a/c. If the “RCPL” considers it necessary for its own protection, it may require the Constituent to immediately on demand deposit funds or securities to their account prior to any applicable settlement date in order to assure due performance of their open contractual commitments. If Constituent does not provide such additional funds or securities, the Constituent hereby grants to the “RCPL” the right to sell any or all securities existing in their account, buy any or all relevant securities which may be short in their account, cancel any or all open orders and/or close any or all outstanding contracts.

(e) In addition, Constituent acknowledges and agrees that the “RCPL” may exercise any or all of the above rights, prior to or without any demand, for additional funds or securities, or notice of sale or purchase, or other notice or intimation. Any such sales or purchases may be made at any time at the sole discretion of the “RCPL” on any market where such business is usually transacted, or at public auction or private sale, or the “RCPL” may purchase/sell for its own account. The making/giving of any prior demand or call or notice of the time and place of such sale or purchase shall not be considered as a waiver of any rights of the “RCPL” to sell or buy without any such demand, call or notice, at that time or at any time subsequently.

(f) In addition to the above, if the Constituent does not credit its funds or securities account as maintained with the “RCPL”, to make up any shortfall in the Margin, instantaneously, to enable restoration of the Margin in Constituent’s account, the position of the Constituent may be squared off by the “RCPL”, without any further reference to the Constituent and without prior notification, and any resultant or associated losses that may occur due to such squaring off shall be borne by the Constituent, and the “RCPL” is hereby fully indemnified and held harmless by the Constituent in this behalf.

In case where the payment by the Constituent towards the Margin is made through a cheque issued in favour of the “RCPL”, any trade would be executed by the “RCPL” only upon the realisation of the funds of the said cheque.

II.vii Confirmations and Contract Notes 

(a) The Constituent is required to ascertain the status of its/his/her order (including any rejection of the same) which would be posted on the relevant sections of the Web-Site or the Constituent may enquire the balance as maintained by RCPL or the RCPL shall keep sending the contract notes and the periodic status of his account wherever the Constituent is availing the services of the “RCPL””off-line” from any terminals of the “RCPL”.

(b) Constituent understands that it is its/his/her responsibility to review, upon first receipt, whether delivered to Constituent by mail, by e-mail, or other electronic means, all confirmations, statements, notices and other communications, including but not limited to, margin, maintenance calls, and prospectuses. Notices and other communications may also be provided to Constituent verbally, in writing or by other means.

(c) The “RCPL” shall deliver to the Constituent via email or other electronic means or otherwise a contract note of the trades executed on their behalf on the trade date, or should post such information on the website, within 24 hours of the execution of the order. The contract note shall be final and binding proof of the order placed by the Constituent and confirmation of trade, regardless of any apparent or inadvertent errors.

(d) All information contained in any confirmation, contract note or other communications shall be binding upon the Constituent in relation to all trades/transactions, whether the orders are given by the Constituent through the Web-Site or by telephonic means or otherwise.

II.viii Charges 

(a) The Constituent agrees to pay the brokerage charges, NSE/BSE related charges, statutory charges/taxes and any other charges (including but not limited to security handling charges on settlement) as they exist from time to time and as they apply to the Constituent’s account, in respect of trades/transactions and services that the Constituent receives from the “RCPL”. The brokerage shall be paid in the manner intimated by the “RCPL” to the Constituent from time to time, including as a percentage of the value of the trade or as a flat fee or otherwise, together with the service tax/securities transaction tax/ sebi charges and other charges as may be applicable from time to time on the same. The Constituent further agrees to pay any applicable taxes that may be levied on the transaction.

(b) The RCPL shall debit the charges of the depository participant for the trades and the bank charges for the realisation of cheques etc. to the Constituent account.

(c) Notwithstanding anything contained in these Terms, any amounts which are overdue from the Constituent to the “RCPL” will be charged delayed payment charges at the rate of [1.5%] per month or such other rate as may be determined by the “RCPL” and notified on the web site and the Constituent hereby authorises the RCPL to directly debit the same to the account of the Constituent.

II.ix Constituents Cash Credit and Securities Accounts 

(a) The “RCPL” shall maintain such books of account in such manner so as to show and distinguish in connection with its business as a trading “RCPL” broker the moneys and securities received from or on account of each of the Constituents, and the moneys and securities received on its own account.
(b) The Constituent is required to ascertain all ledger balances of moneys and securities standing to its credit, which would be posted only on the relevant sections of the web site, and no separate intimation of the ledger balances of the Constituent in his account would be sent to the Constituent either physically or electronically unless specifically requested in writing by the Constituent. The information as contained in the ledger balances shall be binding upon the Constituent and the Constituent hereby agrees that the “RCPL” shall not be liable for any loss, damage or claim on account of any error in the information contained in the ledger balances.

(e) That the Constituent authorises the trading “RCPL” to maintain a running account for me/us/we for adjustment of any debit/credit resulting from any transactions by it/him/her in one settlement for adjustment towards it/her/his credit/debit in subsequent settlements.

(f) All transactions with The Stock Exchange, Mumbai (BSE) and/or the National Stock Exchange of India Limited and / or MCX Stock Exchange Ltd and / or United Stock Exchange of India Ltd (NSE/BSE/MCX-Sx/USE) will be subject to the rules, regulations and Bye-laws of that Exchange apart from the existing terms and conditions as mentioned thereof.

(g) To avoid any ambiguity it is hereby provided that notwithstanding anything contained in these Terms or in the “RCPL”-Constituent Agreement or any other understanding or agreement between the “RCPL” and Constituent, the “RCPL”’s own records of the orders, cancellations, modifications, trades and transactions, in whatsoever manner maintained shall be deemed to be and is hereby accepted by the Constituent as conclusive and binding on the Constituent for all purposes and further the Constituent shall not challenge the accuracy, truth, or correctness of the said records in any manner and for any purpose whatsoever.

II.xi Further Documentation:

The Constituent agrees to complete any further documentation that may be required in relation to any of the securities dealings or by any of the regulatory authorities or under the “RCPL”’s policies as may be notified from time to time or under any law, regulation, guidelines, rule, byelaw, order or other verdict having the force of law.

II.xii Compliance with Laws:

All transactions that are carried out by and on behalf of the Constituent shall be subject to Government notifications, the rules, regulations and guidelines issued by SEBI, the Reserve Bank of India and the National Securities Depository Limited, the Central Depository Services Limited, the Securities Contracts Regulation Act and the rules made there under, and the byelaws, constitution, rules, regulations, customs and usage of the NSE/BSE/MCX-Sx/USE, if any.

III. ADDITIONAL CONDITIONS IN RELATION TO ELECTRONIC ORDERS

III.i List of Dematerialised Securities:

The “RCPL” shall notify the securities for which this facility is made available from time to time on the Web Site. The “RCPL” would have the right to add or delete securities for which the facility is made available in its absolute discretion and details of the same would be posted on the Web Site and no separate intimation whatsoever thereof will be sent to the Constituent.

III.ii Protection of Constituent’s Trading Password :

The Constituent shall immediately notify the “RCPL” in writing, delivered via e-mail, Speed Post and Registered AD, if the Constituent becomes aware of any loss, theft or unauthorised use of the Constituent’s Trading Password and account number; or any failure by the Constituent to receive an accurate written confirmation of an execution including the contract note for the same; or any receipt by the Constituent of confirmation of an order and/or execution which the Constituent did not place; or any inaccurate information in the Constituent’s account balances, securities positions, or transaction history. In the case where the Constituent notifies such loss, theft or unauthorised use of the Constituent’s Trading Password to the “RCPL”, the RCPL shall suspend the use of the account of the Constituent. However, the Constituent shall be responsible and liable for all transactions that are carried out by the use of the Constituent Trading Password. When any of the above circumstances occur, neither the RCPL nor any of its officers, directors, employees, agents, affiliates or subsidiaries will have any responsibility or liability to the Constituent or to any other person whose claim may arise through the Constituent with respect to any of the circumstances described above.

III.iii Use of Constituent’s Trading Password :

The Constituent confirms and agrees that it will be the sole authorised user of the Trading Password /s to be given to it by the “RCPL”. The Constituent accepts sole responsibility for use, confidentiality and protection of the Trading Password /s as well as for all orders and information changes entered into the Constituent’s account using such Trading Password. The Constituent shall ensure that the Trading Password /s is/are not revealed to any third party or recorded in any written or electronic form. If the Constituent forgets the Trading Password, a request for change of the Trading Password should be sent to the “RCPL” in writing. On receipt of such a request the RCPL shall discontinue the use of the old Trading Password and shall generate a new Trading Password for the Constituent, which shall be communicated to the Constituent. However, the Constituent shall be responsible and liable for all transactions that are carried out by the use of the old Trading Password. Neither the “RCPL” nor any of its officers directors employees agents affiliates or subsidiaries will have any responsibility or liability and the the Constituent hereby grants to “RCPL” the right to with-hold its/his/her securities payment and/or funds pay-out from the stock exchange in part or full.

III.iv Form of Trading Password :

The Constituent shall use a Trading Password of 6-8 characters in length, which is a combination of letters and numbers. The Trading Password shall not be a combination relating to name or age or other personal information, which would render it easily deducible. The Trading Password shall be valid for a period of one month only. In the case where the Constituent wishes to change his Trading Password he can do so on the Web Site in the prescribed manner.

III.v Recording of Trading Password :

The Constituent shall memorise the Trading Password and not record it in written or electronic form. In the event that the Constituent does record the Trading Password in written or electronic form, he/she/it shall do so at his/her/its sole risk and responsibility.

III.vi Responsibility for Use of the Trading Password :

Any order entered using the Trading Password is deemed to be that of the Constituent. If third parties gain access to the “RCPL”’s services through the use of the Trading Password, the Constituent will be deemed to be responsible for the same and hereby indemnifies and holds harmless the “RCPL” against any liability, costs or damages arising out of claims or suits by or against such third parties based upon or relating to such access and use, since the primary responsibility for such transaction shall be that of the Constituent.

III.vii Communications Equipment of the Constituent :

The Constituent is responsible for installing and maintaining the communications equipment (including personal computers and modems) and telephone or alternative services required at the Constituent’s end and connectivity required for accessing and using the web site or related services. All communications service charges, levies and fees incurred by the Constituent in accessing the web site or related services will be borne by the Constituent.

III.viii Constituent’s Infrastructure: 

For the purposes of these Terms, it is presumed that the Constituent has all the necessary and compatible infrastructure ready at its end for the purpose of accessing the web site of the RCPL prior to accessing the services provided pursuant to these Terms. The RCPL will not (and shall not be under any obligation to) assist the Constituent in installing the required infrastructure or obtaining the necessary equipment permits and clearances to establish connectivity or linkages to the web site of the “RCPL”.

III.ix Prevention of Unauthorised Use : 

The Constituent will install the necessary safeguards and access restrictions to prevent unauthorised use of Constituents computer systems and ensure that no unauthorised person can gain access to the computer systems.

IV. ADDITIONAL CONDITIONS IN RELATION TO ORAL ORDERS ON-LINE AND OFF-LINE 

(a) The Constituent agrees and hereby authorises the “RCPL” at its sole discretion and without any prior notice to the Constituent, to record any conversation between the Constituent and the “RCPL”. Such recording shall be deemed to be and is hereby accepted by the Constituent as conclusive and binding on the Constituent for all purposes and further the Constituent shall not challenge the accuracy, truth, or correctness of the said records in any manner and for any purpose whatsoever.

(b) The Constituent hereby agrees that the “RCPL” shall not be liable for any losses, damage or claim on account of transactions effected by the “RCPL” on behalf of the Constituent arising from any incorrect or erroneous transfer or collection of the order instructions from the Constituent.

V. RCPL CONSTITUENT COMMUNICATIONS

V.i Form of Communication:

Documents, which may be sent by electronic delivery between the parties, may be in any of the following manners

(a) an electronic mail (‘e-mail’) including any automated replies from the system of the “RCPL”,

(b) an electronic mail attachment, or

(c) in the form of an available download from the web site.

(d) by telephonic information duly recorded.

(e) by courier containing details of transaction confirmations, account statements requisition of any delivery related documents on the last known address of the Constituent.

V.ii Change of Address :

Unless the Constituent informs the “RCPL” of the change of the address for communication in writing, all notices, circulars, communication or mail sent to the existing address shall be deemed to have been received by the Constituent irrespective of whether they are actually received or not.

V.iii Notices/ Policies :

Certain policies and/or procedures may be further outlined on the “RCPL”’s web site and material/literature and frequently asked questions (FAQ’s) may be provided to the Constituent. Through the use of the “RCPL”’s web site and services, the Constituent agrees to be bound by any and all such notices, policies and terms of doing business.

VI. TERMINATION 

(a) The “RCPL”-Constituent Agreement to access to the use of the Web-Site, the Services, the Facilities and the Content may upon notice of one month be terminated by mutual consent of the Constituent and the “RCPL”.

(b) The termination of the “RCPL”-Constituent Agreement and access to the use of the Web-Site, the Services, the Facilities and the Content will not affect the rights and/or obligations of either the “RCPL” or the Constituent incurred prior to the date of such termination and the parties shall enjoy the same rights and shall have the same obligations in respect of such transactions.

(c) The termination of the “RCPL”-Constituent Agreement and access to the use of the Web-Site, the Services, the Facilities and the Content will not affect the rights and/or obligations of either the “RCPL” or the Constituent incurred prior to the date of such termination and the parties shall enjoy the same rights and shall have the same obligations in respect of such transactions.

VII. MISCELLANEOUS INFORMATION 

(a) The Constituent acknowledges and agrees that each participating stock exchange or association or agency asserts a proprietary interest in all of the market data it furnishes to parties that disseminate the said data. The Constituent shall use real-time quotes received on the web site of the “RCPL” only for the Constituent’s individual use and shall not furnish such data to any other person or entity. The Constituent is authorised to use materials which are made available by the “RCPL”’s web site for the Constituent’s own needs only, and the Constituent is not authorised to resell access to any such materials or to make copies of any such materials for sale or use to and by others. The Constituent shall not delete copyright or other intellectual property rights notices from printouts of electronically accessed materials from the “RCPL”’s web site.

(b) All materials published on the Web-Site, including, without limitation, information, text, photographs, images, graphics, software, audio, and video and/or other visual reproductions (hereinafter referred to as the “Content”) are intended solely for personal, non-commercial use. All rights pertaining to the Content or any part thereof shall vest only in the relevant owners of the same and no other person may modify, publish, transmit, participate in the transfer or sale of, reproduce (except as provided herein), create derivative works from, distribute, perform, display or in any way exploit, any of the Content, in whole or in part.

(c) To the extent that any part of the Content may be downloaded or copied, the same may be done only for personal non-commercial purpose(s) and use(s), and provided that all copyright and other notices contained in such Content are faithfully maintained and the Content shall not be stored in any media other than in the Visitor’s personal computer. In the event any software is downloaded from the Web-Site, such software, including without limitation any files, images incorporated in or generated by the software, and data accompanying the software, are licensed to the Visitor by for personal, non-commercial use and viewing only. The software may not be redistributed, sold, decompiled, reverse engineered or otherwise reduced to a human perceivable form. “RCPL” retains full and complete title and rights to all intellectual property in Web Site.

(d) “RCPL”. shall not be liable for truth, accuracy or completeness of the information or for any errors, mistakes or omissions therein or for any delays or interruptions of such information for whatever cause. It is expressly understood and agreed to by the Visitor that except as specifically provided herein, all warranties, express or implied, including any implied warranties or merchantability and/or fitness for a particular purpose, are hereby excluded.

(e) No information, market analysis, research report, etc. on the Website is to be construed as a representation with respect to shares, securities or other investment regarding the legality of an investment therein under the respective applicable investment or similar laws or regulations of any person or entity accessing the Website.

(f) Use of the Service is at any persons, including a Customer’s, own risk. The data and information provided on the Website is not advice, professional or otherwise, and should not be relied upon as such. Neither the information, nor any opinion contained in this Website constitutes a solicitation or offer by “RCPL” to buy or sell any securities, futures, options or other financial instruments or provide any investment advice or service. “RCPL” or their employees have or may have an outstanding buy or sell position or holding in the securities, options on securities or other related investments of issuers and companies mentioned herein. The investments discussed or recommended in the market analysis, research reports, etc. may not be suitable for all investors. Investors must make their own investment decisions based on their specific investment objectives and financial position and using such independent advisors as they believe necessary. Information herein is believed to be reliable but “RCPL” does not warrant its completeness or accuracy. The content of the articles and the interpretation of data are solely the personal views of the contributors and do not in any way reflect the views of “RCPL” Users are advised to peruse the articles and other data in the Website only as information and to rely on their own judgment when making investment decisions.

VII.ii Third Party Providers/Links: 

The Web Site may contain links to other web sites on the World Wide Web. “RCPL”. is not responsible for their resources or their content or the availability thereof.

VII.iii Submissions:

(a) The Visitor shall remain solely responsible for all submissions on and to the Web Site. “RCPL”. is not responsible for the content or message of any submissions. The “RCPL” does not guarantee, and makes no formal representation or warranty as to, the accuracy, veracity or completeness of any information provided by others in any portion or page of the Web-Site, nor does “RCPL” necessarily endorse, support, sanction, encourage, verify, agree with, or reject, diminish or disagree with, the comments, opinions or statements posted by others on the Web-Site.

(b) While “RCPL” does not and cannot review every message posted or item submitted to/on the Web-Site, “RCPL” reserves the right, in its sole discretion, but assumes no duty, to delete, move, or edit submissions that it deems false, inappropriate, abusive, defamatory, obscene, in violation of copyright or trademark laws, or otherwise unacceptable, and the Visitor expressly acknowledges and accepts that its submissions may be edited, removed, modified, published, re-published, transmitted and displayed by in its sole discretion.

(c) The Web Site and its Facilities including the discussion groups and chat rooms shall be used only in a non-commercial manner. No part of the Web Site, discussion groups and/or chat rooms shall be used to solicit Visitors to become users of commercial online information services or for any other commercial services. The Visitor shall not disrupt or interfere with any aspect or element of the Web Site nor shall the Visitor do anything, which, in the sole judgment of “RCPL”, will restrict or inhibit any other Visitor from using and enjoying the Web Site and/or any of its Facilities. The Visitor shall not, without the express written approval of “RCPL”, post or otherwise distribute any material containing any solicitation of funds, advertising or solicitation for goods or services. The Visitor shall not copy third party articles into the chat rooms or discussion groups available on the Web Site. No Visitor shall tout or hype a stock or company, or post the same note on multiple occasions in a single day (a practice known as ‘spamming’). The Visitor shall not upload to, or otherwise submit or publish through, the Web-Site any content or material which is libelous, defamatory, obscene, pornographic, abusive, or hateful, or which invades anyone’s privacy, encourages conduct that would constitute a criminal offense, or otherwise violates any third party rights or local, state, federal or international law or regulation.

(d) Those Visitors with formal connections or affiliations to or with a company being discussed in any forum, including among other things any and all positions of employment, directorships, consultancies and/or substantial share holdings, must identify themselves as such, and disclose such connection or affiliation, within their first post in that topic, company focus, or subject matter.

(e) The author or creator of any and all submissions in print or other forms or other uploads to the discussion groups and/or chat rooms, transfers and assigns to , by virtue of submission to the Web-Site and this agreement, the entire copyright, throughout the universe, in any and all media and forms of publication, reproduction, transmission, distribution, performance, or display,

The provisions of this agreement shall always be subject to government notifications, and rules, regulations & guidelines issued by SEBI & stock exchange rules, regulations & bye-laws that may be in force from time to time & the securities contract regulation Act. The Rules there under and any other applicable statutory provisions and/or regulations.

Now in existence or hereafter developed, in such work or other original materials; without separate, retained or reversionary rights being held by such author, creator or other person submitting such work. “RCPL” may exercise the rights granted herein in such from as it may in its sole discretion determine; such that the submitted material may be published, reproduced, reprinted, distributed, performed, displayed, included in anthologies and compilations, and/or otherwise transmitted (including but not limited to electronic and optical versions and in any other media now in existence or hereafter developed) in whole or in part, whether or not combined with the work of others. In addition, “RCPL” may use the name and electronic address of the author, creator and/or other person submitting the work in publishing, promoting, advertising, and publicizing their publications and information products and services, and in any merchandising.

VII.iv Warranties of Constituent 

(a) The Constituent hereby represents and warrants that the terms and conditions of these Terms have been clearly understood and that the information furnished to the “RCPL” is accurate and truthful

(b) The Constituent confirms that it/he/she is of legal age and he/she/it has obtained the necessary approvals from the relevant regulatory/ legal and compliance authorities to access the services provided pursuant to these Terms.

VII.v Indemnity 

(a) Though orders are generally routed to the marketplace shortly after the time the order is placed by the Constituent on the system there may be a delay in the execution of the order due to any link/system failure at the Constituent/“RCPL”/NSE/BSE/MCX-Sx/USE’s end. The Constituent hereby specifically indemnifies and holds the “RCPL” harmless from any and all claims, and agrees that the “RCPL” shall not be liable for any loss, actual or perceived, caused directly or indirectly by government restriction, exchange or market regulation, suspension of trading, war, strike, equipment failure, communication line failure, system failure, security failure on the Internet, shut down of systems for any reason (including on account of computer viruses), unauthorized access, theft, any fraud committed by any person whether in the employment of the “RCPL” or otherwise or any problem, technological or otherwise, that might prevent the Constituent from entering the “RCPL”’s system or from executing an order or in respect of other conditions

(b) The Constituent further agrees that he/she/it will not be compensated by the “RCPL” for any “lost opportunity’ viz. notional profits on buy/sell orders which could not be executed or real loss from delay in executed orders due to any reason whatsoever, including but not limited to time lag in the execution of the order or the speed at which the system of the RCPL or of the Exchanges is operating or the delay in stock quotes or any shutting down by the RCPL of his system for any reason or the RCPL disabling the Constituent from trading on his system for any reason whatsoever.

VII.vi RCPL’s Liability 

(a) Under no circumstances, including but not limited to negligence, shall the “RCPL” or anyone involved in creating, producing, delivering or managing the Services be liable for any direct, indirect, incidental, special or consequential damages, even if the “RCPL” or such person has been advised of the possibility of such damages, that result from the use of or inability to use the service, delay in transmission of any communication, in each case for any reason whatsoever (including on account of breakdown in systems) or out of any breach of any warranty or due to any fraud committed by any person whether in the employment of the “RCPL” or otherwise.

(b) The Constituent agrees to fully indemnify and hold harmless the “RCPL” for any losses arising from the execution of incorrect/ ambiguous or fraudulent instructions that got entered through the system at the Constituent’s end.

VII.vii Limitation of liability:

The “RCPL” does not guarantee, and shall not be deemed to have guaranteed, the timeliness, sequence, accuracy, completeness, reliability or content of market information, or messages disseminated to the Constituent. The “RCPL” shall not be liable for any inaccuracy, error or delay in, or omission of,

(1) any such data, information or message, or
(2) the transmission or delivery of any such data, information or message; or any loss or damage arising from or occasioned by
(i) any such inaccuracy, error, delay or omission,
(ii) non-performance, or
(iii)interruption in any such data, information or message, due either to any act or omission by the “RCPL” or to any “force majeure” event (e.g., flood, extraordinary weather condition, earthquake or other act of God, fire, war, insurrection, riot, labour dispute, accident, action of government, communications, power failure, shut down of systems for any reason (including on account of computer viruses), equipment or software malfunction), any fraud committed by any person whether in the employment of the “RCPL”or otherwise or any other cause beyond the reasonable control of the “RCPL”.

VII.viii Interruption in service:

The “RCPL” does not warrant that the service will be uninterrupted or error free. The service is provided on an “as is” and “as available” basis without warranties of any kind, either express or implied, including, without limitation, those of merchantability and fitness for a particular purpose. The Constituent agrees that the “RCPL” shall not be held responsible for any breakdown of the system either due to the fault of the systems of the “RCPL”or of the Exchanges or otherwise.

VII.ix Amendment/ Modification of the Terms :

The “RCPL” may at any time amend these Terms, by modifying or rescinding any of the existing provisions or conditions or by adding any new provision or condition, by conspicuously posting notice of such amendment on the web site. The “RCPL” shall not be required to communicate any modification or rescission to the Constituent either through physical or electronic form, and any notice of amendment or modification is hereby waived by the Constituent. The continued use of the services of the “RCPL” after such notice will constitute acknowledgement and acceptance of such amendment. These Terms (as amended or modified from time to time) represent the entire agreement between the Constituent and the “RCPL” concerning the subject matter hereof. The continued use of the Services by the Constituent constitutes the Constituent’s acceptance of any and all modifications and amendments of the Terms.

VII.x Severability :

If any provisions or of these Terms are held invalid or unenforceable by reason of any law, rule, administrative order or judicial decision by any court, or regulatory or self-regulatory agency or body, such invalidity or unenforceability shall attach only to such provision or terms held invalid. The validity of the remaining provisions and terms shall not be affected thereby and these Terms shall be carried out as if any such invalid or unenforceable provisions or terms were not contained herein.

VII.xi No Assignment :

The rights of the Constituent under these Terms are not transferable under any circumstances and shall be used only by the Constituent.

VII.xii Authorised Representative:

The instructions issued by an authorised representative of the Constituent shall be binding on the Constituent in accordance with the letter authorising the said representative to deal on behalf of the Constituent.

VII.xiii Death or Insolvency:

In the event of death or insolvency of the Constituent or of its otherwise becoming incapable of receiving and/or paying for or delivering or transferring securities which the Constituent has ordered to be bought or sold, the “RCPL” may close out the transaction of the Constituent and the Constituent or its legal representative/s or nominee/s shall be liable jointly or severally for any losses, costs and be entitled to any surplus which may result there from.

VII.xiv Dispute Resolution 

(a) The “RCPL” and the Constituent are aware of the provisions of the bye laws rules and regulations of the NSE/BSE/ MCX-Sx/USE relating to the resolution of the disputes/differences through the mechanism of arbitration provided by the Exchanges and agree to abide by the said provisions insofar as any disputes under these Terms relate to transactions that are to be carried out on the exchanges.

(b) In so far as any other disputes or differences in connection with these Terms or their performance (other than the disputes referred to in Paragraph VII.XIV(a) above) are concerned such disputes shall, so far as it is possible, be settled amicably between the Parties and in the case where after 30 days of consultation, the parties have failed to reach an amicable settlement, such disputes shall be submitted to arbitration and such arbitration shall be conducted in accordance with the Indian Arbitration and Conciliation Act, 1996 (the “Arbitration Act”) by an panel consisting of a sole arbitrator. The “RCPL” and the Constituent expressly consent and agree that the Chairman, shall be the persona designate to appoint the dais sole arbitrator. The venue of arbitration shall be Agra i and each party shall bear the cost of arbitration equally unless otherwise awarded by the sole arbitrator.

(c) The “RCPL” maintains offices at different places within the knowledge of the Constituent and the Constituent shall have all transaction with the principle office, but they may also avail facility at its branches as well. Branch Managers shall also have the power to recover payments or make the payments on behalf of the principles to such Constituents after obtaining the instruction in this behalf and may give acknowledgement of such transaction on behalf of the head office. However all transaction may be entered at branches shall be treated as transaction being done with the principle office and all information shall remain with the “RCPL” at “Agra”.

VII.xv Foreign Jurisdiction 

This service does not constitute an offer to sell or a solicitation of an offer to buy any shares, securities or other instruments to any person in any jurisdiction where it is unlawful to make such an offer or solicitation. This service is not intended to be any form of an investment advertisement, investment advice or investment information and has not been registered under any securities law of any foreign jurisdiction and is only for the information of any person in any jurisdiction where it may be lawful to offer such a service. Further, no information on the Web Site is to be construed as a representation with respect to shares, securities or other investments regarding the legality of an investment therein under the respective applicable investment or similar laws or regulations of any person or entity accessing the Web Site.

VII.xvi General

(a) Notwithstanding anything contained in these Terms or in the “RCPL” -Constituent Agreement, “RCPL” retains its right to:
(i) In its sole discretion to alter, limit or discontinue the Website or any Material/s in any respect. “RCPL”shall have no obligation to take the needs of any user into consideration in connection therewith.
(ii) Deny in its sole discretion any user access to this Website or any portion thereof without notice.
(b) No waiver by of any provision of this Agreement shall be binding except as set forth in writing signed by its duly authorised representative.

VII.xvii Other General Terms and Conditions. 

(a) The Constituent agrees to abide by the “RCPL” Terms and Conditions and rules in force and changes in Terms and Conditions from time to time relating to their account.

(b) The Constituent agrees that the “RCPL” will be at liberty to close their account any time without assigning any reason whatsoever.

(c) The Constituent agrees that the “RCPL” can, at its sole discretion, withdraw any of the services/facilities given in their account either wholly or partially at any time without giving them any notice.

(d) The Constituent agrees that any change in their account status or change of address will be immediately informed to the “RCPL”.

(e) The Constituent agrees that all instructions relating to their account will be issued in writing satisfactory to the “RCPL” in form and content.

(f) The Constituent agrees that they shall not pay any amount in cash to any Sales Representative of the “RCPL” at the time of opening an account or carrying out any transaction in the normal course of the business.

(g) The Constituent agrees to accept the format provided by the “RCPL” in order to execute their fax instructions to the

(h) The Constituent agrees that the “RCPL” will send them communications/letters etc. through courier / messenger/mail or through any other mode at its discretion and the “RCPL” shall not be liable for any loss or delay arising there from.

(i) The Constituent agrees that the Pass Words will be dispatched by courier /email (or any other mode at the “RCPL” discretion) at their risk and consequence.

(j) The Constituent shall not hold the “RCPL” liable in any manner what so ever in respect of such dispatch of these items.< br>
(k) An account may be opened on behalf of a minor by his/her natural guardian or by a guardian appointed by a court of Competent Jurisdiction. The guardian shall represent the minor in all transactions of any description in the above account until the said minor attains majority. Upon the minor attaining majority, the right of the guardian to operate the account shall cease. The guardian agrees to indemnify the “RCPL” against the claim of above minor for any withdrawal/transactions made by him in the minor’s account.

(l) The Constituent agrees and undertakes to ensure that there would be sufficient funds/cleared balance/pre-arranged credit facilities in their account for effecting transactions. The Constituent agrees that the “RCPL” shall not be liable for any consequences arising out of non-compliance by the “RCPL” of my instructions due to inadequacy of funds and the “RCPL” can at its sole discretion decide to carry out the instructions notwithstanding the inadequacy of funds. There “RCPL” may do the aforesaid without prior approval from or notice to them and they shall be liable to repay with interest the resulting advance, overdraft or credit thereby created and all related charges arising thereby @ 18% compounded daily basis.

(m) The Constituent agrees that the “RCPL”. shall not be liable for any damages, losses (direct or indirect) whatsoever, due to disruption or non availability of any of services/facility/s due to technical fault/error or any failure in telecommunication network or any error in any software or hardware systems.

(n) The Constituent agrees that the “RCPL”. may disclose customer information, in strict confidence, to any of its agent/s and/or contractors with whom the “RCPL”. enters or has entered into any arrangement in connection with providing of services.

VII.xviii Accounts:

The Constituent agrees to repay to the “RCPL” on demand, unconditionally, the amounts of overdrafts or excesses against margin deposit that the “RCPL” may grant it/he/her from time to time, together with interest accrued thereon. The Constituent agrees that this does not imply that the “RCPL” is bound to grant them any credit or other facility whatsoever.

VIII.ii Internet: 

Internet refers to the network of computers / mobile phones / other electronic devices which share and exchange information. The Internet is at once a worldwide broadcasting capability, mechanism for information dissemination, and a medium for collaboration and interaction between individuals and their computers / mobile phones / other electronic devices capable of accessing the Internet without regard for geographic location.

VIII.iv Customer :

Customer refers to any person who has a “RCPL”. Account and who has been authorised by the “RCPL”. to avail of the said facility.

VIII.v Account :

Account refers to the Customer’s Savings and/or Current Account to which access is to be obtained through Electronic Payment Gateway for Netbanking.

VIII.vi Personal Information:

Personal Information refers to the information about the Customer obtained in connection with Electronic Payment Gateway for Netbanking or otherwise.

1.Policies & Procedures as per SEBI guidelines

1. Refusal of orders for penny / illiquid stock

The stock broker may from time to time limit (quantity/value) refuse orders in one or more securities due to various reasons including market liquidity, value of security (ies), the order being for securities which are not in the permitted list of the stock Broker/exchange(s)/SEBI. Provided further that stock broker may require compulsory settlement/advance payment of expected settlement value/delivery of securities for settlement prior to acceptance/ placement of order(s) as well. The client agrees that the losses, if any on account of such refusal or due to delay caused by such limits, shall be borne exclusively by the client alone. The stock broker may require reconfirmation of orders, which are larger than that specified by the stock broker’s risk management, and is also aware that the stock broker has the discretion to reject the execution of such orders based on its risk perception.

2.Setting up client’s exposure limits and conditions under which a client may not be allowed to take further position or the broker may close the existing position of a client

The stock broker may from time to time impose and vary limits on the orders that the client can place through the stock broker’s trading system (including exposure limits, turnover limits, limits as to the number, value and/or kind of securities in respect of which orders can be placed etc.). The client is aware and agrees that the stock broker may need to vary or reduce the limits or impose new limits urgently on the basis of the stock broker’s risk perception and other factors considered relevant by the stock broker including but not limited to limits on account of exchange/ SEBI direction/limits (such as broker level/ market level limits in security specific/volume specific exposures etc.), and the stock broker may be unable to inform the client of such variation, reduction or imposition in advance. The client agree that the stock broker shall not be responsible for such variation, reduction or imposition or the client’s inability to route any order through the stock broker’s trading system on account of any such variation, reduction or imposition of limits. The client further agrees that the stock broker may at any time, at its sole discretion and without prior notice, prohibit or restrict the client’s ability to place orders or trade in securities through the stock broker, or it may subject any order placed by the client to a review before its entry into the trading systems and may refuse to execute/allow execution of orders due to but not limited to the reason of lack of margin/securities or the order being outside the limits set by stock broker/exchange/SEBI and any other reason which the stock broker may deem appropriate in the circumstances. The client agrees that the losses, if any on account of such refusal or due to delay caused by such review, shall be borne exclusively by the client alone.

The stock broker is required only to communicate/advise the parameters for the calculation of the margin/security requirements as rate (s)/percentage(s) of the dealings, through anyone or more means or methods such as post /speed post/courier / registered post/registered A.D/facsimile/telegram/cable/e-mail/voice mails/telephone (telephone includes such devices as mobile phones etc.) including SMS on the mobile phone or any other similar device; by messaging on the computer screen of the client’s computer; by informing the client through employees/agents of the stock broker; by publishing/displaying it on the website of the stock broker/making it available as a download from the website of the stock broker; by displaying it on the notice board of the branch/office through which the client trades or if the circumstances, so require, by radio broadcast/television broadcast/newspapers advertisements etc; or any other suitable or applicable mode or manner. The client agrees that the postal department/the courier company /newspaper company and the e-mail/ voice mail service provider and such other service providers shall be the agent of the client and the delivery shall be complete when communication is given to the postal department/the courier company /the e-mail /voice mail service provider, etc. by the stock broker and the client agrees never to challenge the same on any grounds including delayed receipt/non receipt or any other reasons whatsoever and once parameters for margin/security requirements are so communicated, the client shall monitor his/her/its position (dealings/trades and valuation of security) on his/her/its own and provide the required/deficit margin/security forthwith as required from time to time whether or not any margin call or such other separate communication to that effect is sent by the stock broker to the client and/ or whether or not such communication is received by the client.

The client is not entitled it trade without adequate margin/security and that it shall be his/her/its responsibility to ascertain beforehand the margin /security requirements for his/her /its orders/trades/deals and to ensure that the required margin/security is made available to the stock broker in such form and manner as may be required by the stock broker. If the client’s order is executed despite a shortfall in the available margin, the client, shall, Whether or not the stock broker intimates such shortfall in the margin to the client, make up the shortfall suo moto immediately. The client further agrees that he/she/it shall be responsible for all orders (including any orders that may be executed without the required margin in the client’s account) &/or any claim /loss/damage arising out of the non availability / shortage of margin / security required by the stock broker &/or exchange &/or SEBI.

The stock broker is entitled to vary the form (Le., the replacement of the margin/security in one form with the margin/security in any other form, say, in the form of money instead of share) &/or quantum &/or percentage of the margin &/or security required to be deposited/made available, from time to time.

The margin/security deposited by the client with the stock broker are not eligible for any interest.

The stock broker is entitled to include/appropriate any/all payout of fund &/or securities towards margin/security without requiring specific authorizations for each payout.

The stock broker is entitled to transfer funds &/ or securities from his account for one exchange &/or one segment of the exchange to his/her/its account for another exchange &/or another segment of the same exchange whenever applicable and found necessary by the stock broker.

The client also agrees and authorises the stock broker to treat/adjust his/her/its margin/security lying in one exchange &/or one segment of the exchange/towards the margin/security/pay in requirements of another exchange &/or another segment of the exchange.

The stock broker is entitled to disable/freeze the account &/or trading facility/any other service. Facility, if, in the opinion of the stock broker, the client has committed a crime/fraud or has acted in contradiction of this agreement or/is likely to evade/violate any laws, rules, regulations, directions of a lawful authority whether Indian or foreign or if the stock broker so apprehends.

3.Applicable brokerage rate

The stock broker is entitled to charge brokerage within limits imposed by exchange which at present is as under:
a. For Cash Market Segment: The maximum brokerage chargeable in relation to trades effected in the securities admitted to dealings on the Capital Market segment of the exchange shall be 2.5% of the contract price exclusive of statutory levies. It is hereby further clarified that where the sale/purchase value of a share is Rs. 10/- or less a maximum brokerage of 25 paise per share may be collected.
b. For Option contracts: Brokerage for option contracts shall be charged on the premium amount at which the option contract was bought or sold and not on the strike price of the option contract. It is hereby clarified that brokerage charged on options contracts shall not exceed 2.5% of the premium amount or Rs. 100/ – (per lot) whichever is higher.

4.Imposition of penalty / delayed payment charges

The client agrees that any amounts which are overdue from the client towards trading or on account of any other reason to stock broker will be charged with delayed payment charges at such rates as may be determined by the stock broker .The client agrees that the stock broker may impose fines/penalties for any orders/trades/deals/actions of the client which are contrary to this agreement/rules/regulations/bye laws of the exchange or any other law for the time being in force, at such rates and in such form as it may deem fit. Further where the stock broker has to pay any fine or bear any punishment from any authority in connection with/as a consequence of/in relation to any of the orders/trades/deals/actions of the client, the same shall be borne by the client. The client agrees to pay to the stock broker brokerage, commission, fees, all taxes, duties, levies imposed by any authority including but not limited to the stock exchanges (including any amount due on account of reassessment/backlogs etc.), transaction expenses, incidental expenses such as postage, courier etc. as they apply from time to time to the client’s account/transactions/services that the client avails from the stock broker.

5.The right to sell clients ’ securities or close clients ’ positions, without giving notice to the client, on account\ of non-payment of client’s dues

The stock broker maintains centralized banking and securities handling processes and related banking and depository accounts at designated place. The client shall ensure timely availability of funds/securities in designated form and manner at designated time and in designated bank and depository account(s) at designated place, for meeting his/her/its pay in obligation of funds and securities. The stock broker shall not be responsible for any claim/loss/damage arising out of non availability/short availability of funds/securities by the client in the designated account(s) of the stock broker for meeting the pay in obligation of either funds or securities. If the client gives orders /trades in the anticipation of the required securities being available subsequently for pay in through anticipated payout from the exchange or through borrowings or any off market delivery(s) or market delivery(s) and if such anticipated availability does not materialize in actual availability of securities/funds for pay in for any reason whatsoever including but not limited to any delays/shortages at the exchange or stock broker level/non release of margin by the stock broker etc., the losses which may occur to the client as a consequence of such shortages in any manner such as on account of auctions/square off/closing outs etc., shall be solely to the account of the client and the client agrees not to hold the stock broker responsible for the same in any form or manner whatsoever.

In case the payment of the margin/security is made by the client through a bank instrument, the stock broker shall be at liberty to give the benefit/credit for the same only on the realization of the funds from the said bank instrument etc. at the absolute discretion of the stock broker.

Where the margin/security is made available by way of securities or any other property, the stock broker is empowered to decline its acceptance as margin/security &/or to accept it at such reduced value as the stock broker may deem fit by applying haircuts or by valuing it by marking it to market or by any other method as the stock broker may deem fit in its absolute discretion.

The stock broker has the right but not the obligation, to cancel all pending orders and to sell/close/liquidate all open positions/securities/share at the pre-defined square off time or when mark to market (M-T-M) percentage reaches or crosses stipulated margin percentage mentioned on the website, whichever is earlier. The stock broker will have sole discretion to decide referred stipulated margin percentage depending upon the market condition. In the event of such square off, the client agrees to bear all the losses based on actual executed prices. In case open position (Le. short/long) gets converted into delivery due to non square off because of any reason whatsoever, the client agrees to provide securities/funds to fulfill the payin obligation failing which the client will have to face auctions or internal close outs; in addition to this the client will have to pay penalties and charges levied by exchange in actual and losses, if any. Without prejudice to the foregoing, the client shall also be solely liable for all and any penalties and charges levied by the exchange(s).

The stock broker is entitled to prescribe the date and time by which the margin/security is to be made available and the stock broker may refuse to accept ant payments in any form after such deadline for margin/security expires.

Notwithstanding anything to the contrary in the agreement or elsewhere, if the client fails to maintain or provide the required margin/fund/security or to meet the funds/margins/securities pay in obligations for the orders/trades/deals of the client within the prescribed time and form, the stock broker shall have the right without any further notice or communication to the client to take any one or more of the following steps:

1.     To withhold any payout of funds/securities.

2.     To withhold/disable the trading/dealing facility to the client.

3.     To liquidate one or more security(s) of the client by selling the same in such manner and at such rate which the stock broker may deem fit in its absolute discretion. It is agreed and understood by the client that securities here includes securities which are pending delivery/receipt.

4.    To liquidate/square off partially or fully the position of sale &/or purchase in anyone or more securities/contracts in such manner and at such rate which the stock broker may decide in its absolute discretion.

5.   To take any other steps which in the given circumstances, the stock broker may deem fit.
The client agrees that the loss(s) if any, on account of anyone or more steps as enumerated herein above being taken by the stock broker, shall be borne exclusively by the client alone and agrees not to question the reasonableness, requirements, timing, manner, form, pricing etc., which are chosen by the stock broker.

6. Shortages in obligations arising out of internal netting of trades

Stock broker shall not be obliged to deliver any securities or pay any money to the client unless and until the same has been received by the stock broker from the exchange, the clearing corporation/ clearing house or other company or entity liable to make the payment and the client has fulfilled his/her/its obligations first. The policy and procedure for settlement of shortages in obligations arising out of internal netting of trades is as under:

1. The securities delivered short are purchased from market on T+3 day which is the Auction Day on Exchange, and the purchase consideration (inclusive of all statutory taxes & levies) is debited to the short delivering seller client.

2. If securities cannot be purchased from market due to any reason whatsoever on T+3 day they can be covered from the market on any subsequent trading days. In case any reason whatsoever (any error or omission) any delay in covering of securities leads to higher losses, stock broker will not be liable for the same. Where the delivery is matched partially or fully at the Exchange Clearing, the delivery and debits/credits shall be as per Exchange Debits and Credits.

3.In cases of securities having corporate actions all cases of short delivery of cum transactions which cannot be auctioned on cum basis or where the cum basis auction payout is after the book closure/record date, would be compulsory closed out at higher of 10% above the official closing price on the auction day or the highest traded price from first trading day of the settlement till the auction day.

7.Conditions under which a client may not be allowed to take further position or the broker may close the exiting position of a client.

We have margin based RMS System. Client may take exposure upto the amount of margin available with us. Client may not be allowed to take position in case of non-availability/shortage of margin as per our RMS policy of the company. The existing position of the client is also liable to square off/close out without giving notice due to shortage of margin/non making of payment for their pay-in obligation/outstanding debts.

8. De-registering a client

Notwithstanding anything to the contrary stated in the agreement, the stock broker shall be entitled to terminate the agreement with immediate effect in any of the following circumstances:

•If the action of the Client are prima facie illegal/improper or such as to manipulate the price of any securities or disturb the normal/proper functioning of the market, either alone or in conjuction with others.
•If there is any commencement of a legal process against the Client under any law in force;
On the death/lunacy or other disability of the Client;
•If a receiver, administrator or liquidator has been appointed or allowed to be appointed of all or any part of the undertaking of the Client;
•If the Client has voluntarily or compulsorily become the subject of proceedings under any bankruptcy or insolvency law or being a company, goes into liquidation or has a receiver appointed in respect of its assets or refers itself to the Board for Industrial and Financial Reconstruction or under any other law providing protection as a relief undertaking;
•If the Client being a partnership firm, has any steps taken by the Client and/or its partners for dissolution of the partnership;
•If the Client have taken or suffered to be taken any action for its reorganization, liquidation or dissolution;
•If the Client has made any material misrepresentation of facts, including (without limitation) in relation to the security;
•If there is reasonable apprehension that the Client is unable to pay its debts or the Client has admitted its inability to pay its debts, as they become payable;
•If the Client suffers any adverse material change in his/her/its/financial position or defaults in any other agreement with the Stock broker;
•If the Client is in breach of any term, condition or covenant of this Agreement;
•If any covenant or warranty of the Client is incorrect or untrue in any material respect; However notwithstanding any termination of the agreement, all transactions made under/pursuant to this agreement shall be subject to all the terms and conditions of this agreement and parties to this agreement submit to exclusive jurisdiction of courts of law at the place of execution of this agreement by Stock Broker.

9.Policy regarding treatment of inactive account

Client account will be considered as inactive if the client does not trade for a period of one year. Calculation will be done at the beginning of every month and those clients who have not traded even a single time will be considered as inactive. Steps will be taken for transferring the shares/credit balance, if any, to such client within one week of identifying the client as inactive. Whenever such inactive account holders restart trading, a telephonic / personal confirmation will be made from the client to ensure that there is no error in identification of the client.

1.Arbitration Policy

1. All claims,differences or disputes between the Trading Members inter se and between Trading Members and Constituents arising out of or in relation to dealings,contracts and transactions made subject to the Bye-Laws,Rules and Regulations of the Exchange or with reference to anything incidental thereto or in pursuance thereof or relating to their validity,construction,interpretation,fulfilment or the rights,obligations and liabilities of the parties thereto and including any question of whether such dealings,transactions and contracts have been entered into or not shall be submitted to arbitration in accordance with the provisions of these Bye-Laws and Regulations.
2. In all dealings,contracts and transactions,which are made or deemed to be made subject to the Bye-Laws,Rules and Regulations of the Exchange,the provisions relating to arbitration as provided in these Bye-Laws and Regulations shall form and shall be deemed to form part of the dealings,contracts and transactions and the parties shall be deemed to have entered into an arbitration agreement in writing by which all claims,differences or disputes of the nature referred to in clause(1) above shall be submitted to arbitration as per the provisions of these Bye-Laws and Regulations.
3. All Claims,differences or disputes referred to in clause(1) above shall be submitted to arbitration within six months from the date on which the claim, difference or dispute arose or shall be deemed to have arisen.The time taken in conciliation proceedings,if any,initiated and conducted as per the provisions of the Act and the time taken by relevant authority to administratively resolve the claim,differences or disputes shall be excluded for the purpose of determining the period of six months.
4. Save as otherwise specified by the Relevant Authority the seat of arbitration for different regions shall be as follow:

 5.Save as otherwise specified by the Relevant Authority,the criteria for selection of seat of arbitration for a particular matter is as follows

6.Unless otherwise specifically agreed in writing between the Trading Member and the Constituent, in respect of any claims, disputes and differences arising out of internet trading between the Constituent and Trading Member, the seat of arbitration shall be the Regional Arbitration Centre within the area in which the Constituent ordinarily resided at the time of relevant trading, provided however in respect of a Non-Resident Indian Constituent, the seat of arbitration shall be the RAC in the area of which the correspondence office of the Trading Member is situated.

*”TM” stands for “Trading Member” and “c” stands for “Constituent”
For more details please refer to Chapter XI of the Bye-Laws and Chapter 5 of Capital Market Trading Regulations of The National Stock Exchange of India Ltd.

 Anti Money Laundering Policy

Back ground

The Prevention of Money Laundering Act, 2002 came into effect from 1^st July 2005. SEBI vide circular dated 18^th January 2006 required market intermediaries to lay down policy framework for A nti Money Laundering measures to be followed. SEBI has also issued Master   Circular dated 19^th December 2008 & circular CIR/MIRSD/1/2014 dt. 12.03.2014. Subsequently amended in Prevention of Money Laundering (Maintenance of Records) Rules, 2005 as per the gazette notification dated June 1, 2017.

 The   PMLA   2002   and    Rules   notified thereunder   impose an obligation on intermediaries to verify identity of clients, maintain records and furnish information to the Financial Intelligence Unit (FIU)-India.

What is Money  Laundering?

Money  Laundering defined as cleansing of dirty  money obtained from legitimate or illegitimate activities including drug trafficking, terrorism, organized crime,  fraud and  many  other  crimes  with  the  objective  of hiding its source  and  rendering it in legally  usable  form.  It is any act or attempted act to conceal or disguise the identity of illegally obtained proceeds so that they appear to have originated from legitimate sources. The  process of  money  laundering  involves creating  a  web  of  financial transactions so as to hide the origin  of and true nature of these funds.

This is done three phases- placement Phase, Layering Phase & Integration Phase.

Objectives

The Prevention of Money Laundering Act, 2002 (PMLA) forms the core of the legal framework put in place by India to combat money laundering. PMLA and the Rules notified there under came into force with effect from July 1, 2005.

The PMLA and rules notified there under impose obligation on banking companies, financial institution and intermediaries to verify identity of clients, maintain records and furnish information to FIU-INDIA. PMLA defines money laundering offence and provides for the freezing, seizure and confiscation of the proceeds of crime. Monitor / maintain record of all cash transactions of the value of more than Rs. 10 lacs or its equivalent in foreign currency.

Policy of Raghunandan Capital Private Limited

Raghunandan Capital Private Limited has resolved  that   it  would,  as  an  internal  policy,   take   adequate measures to prevent money laundering and  shall put  in place a frame  work  to report cash and  suspicious transactions to FIU as per the guidelines of PMLA Rules, 2002.

Implementation of this Policy

Mr. Rahil Uddin is the Principal Officer  who  is responsible for compliance of the provision of the PMLA and  AML Guidelines act as a central  reference point  and  play  an  active  role  in  identification & assessment of potentially  suspicious  transactions. Ensure that Group discharges its legal obligations to report suspicious transaction to the concerned authorities.

Rights and Powers of Principal Officer

The principal officer ensures that:-

1. The PMLA Guidelines and the Board approved PMLA Policy is implemented effectively by the company.
2. The identification and assessment of potentially suspicious transactions are done on the regular basis.
3. The company is regularly updated regarding any changes/additions/modification in PMLA Provisions.
4. The company reports the suspicious transactions to the concerned authorities within the specific time as per the PMLA policy.
5. The company responds promptly to any request for information, including KYC related information, made by the regulators, FIR-IND and other statutory authorities. Any other responsibilities assigned. Designated director will implement the PMLA guidelines issued by SEBI time to time.

The main aspect of this policy is the customer due diligence process which  means:-

1. Obtaining sufficient information about to the client in order to identify who  is the actual  beneficial  owner of the securities or on whose  behalf  transaction is conducted;
2. Verify the  customers identity using  reliable  independent source  documents, data  or information;
3. Conduct on-going due diligence and scrutiny of the account/client to ensure that the transaction conducted  are  consistent  with   the  clients’ background / financial status, its activities and risk profile.

The customer due diligence process includes three specific parameters:-

• Elements of Client Due Diligence;
• Client Identification Procedure;
• Clients of special category (CSC)
• Policy for acceptance of clients;
• Risk Based Approach
• Suspicious Transaction identification and reporting.

(A) Element of Client Due Diligence (CDD)

The CDD measures comprise the following:

1. Obtaining sufficient information in order to identify persons who beneficially own or control the securities account. Whenever it is apparent that the securities acquired or maintained through an account are beneficially owned by a party other than the client, that party shall   be identified using   client identification and verification procedures. The beneficial owner is the natural person or persons who ultimately own, control or influence a client and/or persons on whose   behalf a transaction is  being   It also incorporates those   persons who   exercise ultimate effective control over a legal person or arrangement.
2. Verify the client’s identity using reliable, independent source documents, data or information;
3. Identify beneficial ownership and   control, i.e. determine which   individual(s) ultimately own(s) or control(s) the client and/or the person on whose behalf a transaction is being conducted;
4. Verify the  identity of the  beneficial  owner of the  client  and/or the  person on whose   behalf   a  transaction  is  being   conducted,  corroborating  the   information provided in relation to (c);
5. Understand the ownership and control structure of the client;
6. Conduct ongoing due  diligence and  scrutiny, i.e. Perform ongoing scrutiny of the transactions  and   account throughout  the  course   of  the  business  relationship  to ensure that   the  transactions being   conducted  are  consistent  with   the  registered intermediary’s knowledge of  the  client,  its  business and  risk  profile,   taking   into account, where necessary, the client’s source  of funds;  and
7. Registered intermediaries shall periodically update all documents, data or information of all clients and beneficial owners collected under the CDD process.

Reliance on third party for carrying out Client Due Diligence (CDD)   

1. We should  rely   on  a  third  party  for  the   purpose  of  (a)  identification  and verification of the  identity of a client  and  (b) determination of whether the  client  is acting  on  behalf  of a  beneficial  owner, identification of the  beneficial  owner and verification  of  the   identity  of  the   beneficial     Such   third  party  shall   be regulated, supervised or monitored for, and  have  measures in place  for compliance with  CDD  and  record-keeping requirements in line  with  the  obligations under the PML Act.
2. Such reliance shall  be subject  to the  conditions that  are specified in Rule 9 (2) of the  PML  Rules  and   shall  be  in  accordance  with   the  regulations  and   circulars/ guidelines issued by SEBI from time to time. Further, it is clarified  that the registered intermediary shall  be  ultimately responsible for  CDD  and  undertaking enhanced due diligence measures, as applicable.

(B) Client Identification Procedure

To have  a mechanism in place  to establish identity of the client  along  firm proof  of address  to   prevent  opening  of  any   account  which   is  fictitious  / benami  / anonymous in nature.

There are following documents/activities upon which  we can rely:-

1. PAN Card : PAN Card  is mandatory and is most reliable  We can independently check its genuineness through Income  Tax website.
2. Identity Proof : PAN Card,  itself can serve  as proof  of identity . However, in case PAN  card  carries  an old photograph of the holder, which  does  not match  current facial features of the client, we should take other  identity proof  in form  of Voter’s identity card,  Passport, Ration  Card  or any Government/PSU/Bank issued photo identity card.
3. Address Proof : For  valid  address proof  we  can  rely  on  voter’s identity card, Passport, Bank  Statement, ration  card  and  latest  Electricity/telephone bill in the name  of the client.
4. In person Verification:- In person Verification of the client to be done as per Rule, Guidelines etc.
5. Monitoring of Trading  activities:-RMS department  should monitor the  trading activity  of the client and  exercise due  diligence to ensure that the trading activities of the client  is not disproportionate to the financial status and  the track  record of the client.
6. Acceptance of Payment:-It  should be  insured that  payment  received from  the client is being  received in time and  through the bank  account the details  of which are  given   by  the   client   in  KYC  application  form   and   the  payment  through cash/bearer demand draft  should not be entertained.

Documents to be  obtained as  part   of  customer identification procedure  for  new clients:

1. In case of individual, one copy of the following documents has to be obtained:

PAN  Card,  it is mandatory, it can  be verified its genuineness with  Income Tax website and  cross  verify  the  PAN  card  copy  with  the  original. “verified with  original”  stamp should be taken  as proof  of verification. Other  proofs for identity are voter’s identity card, Passport, Ration  Card  or any Government/PSU/bank issued photo identity card  or any  other  documents prescribed by the regulatory authorities.

Address proof  in the form of voter’s identity card,  Passport, Bank Statement, Ration  Card  and  latest  Electricity/telephone bill in the name  of the client  or any other  document prescribed by the regulatory authorities.

1. In case  of  corporate, one  certified copy  of  the  following documents  must   be obtained:-

Copy of the Registration/Incorporation Certificate;

Copy of the Memorandum & Articles of the Association;

Copy of the latest audited Annual Statement of the corporate client;

Latest Income  Tax return filed with Income  Tax deptt.;

Latest Net worth Certification;

Copy of the PAN card and the Director index No.(DIN);

Board   Resolution  for  appointment  of  the   Authorized  Person   who   will operate the account;

Proof of address and any identity of Authorized Person

1. In case of partnership firm one certified copy of the following must be obtained:-

Partnership Deed;

Registration certificate;

Authorization  letter   for  the  person authorized  to  open   and   operate the     account

Annual statement/returns of the partnership firm

PAN card of partners;

Proof of identity and address of the authorized person.

1. In case of a Trust, one certified copy of the following must be obtained:-

Trust Deed;

Registration certificate;

Officially   valid   documents  like   PAN   card,   voters   ID,  Passport,  etc  of

person(s) authorized to transact on behalf of the trust;

PAN card;     Authorization letter for the entity  authorized to act on their behalf.

1. In case of unincorporated association or a body of individuals, one certified copy

of the following must  be obtained:

Officially valid  documents like PAN Card,  Voters ID, passport, etc of the person(s) authorized to transact;

POA in favour person authorized to transact;

Resolution of the managing body  of such association or body  of individuals;

Any document required to establish the legal existence of such an association or body  of individual.

1. In case of an NRI account- Repatriable/non-repatriable, the following documents

are required:

Copy of the passport;

Copy of the PIS permission issued by the bank;

Copy of the bank statement copy of the demat statement;

Copy of PAN card;

Proof of overseas address and  Indian address;

If the account is handled through a mandate holder, copy of the valid  POA/mandate.

Further, as per amendments to the Prevention of Money laundering (Maintenance of Records) Rules, 2005, it is stated as below:-

“Provided that in case of officially valid document furnished by the client does not contain updated address, the following documents shall be deemed to be officially valid documents for the limited purpose of proof of address:-

• utility bill which is not more than two months old of any service provider (electricity, telephone, post-paid mobile phone, piped gas, water bill);
• property or Municipal tax receipt;
• pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings, if they contain the address;
• letter of allotment of accommodation from employer issued by State Government or Central Government Departments, statutory or regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions and listed companies and leave and licence agreements with such employers allotting official accommodation; Provided further that the client shall submit updated officially valid document with current address within a period of three months of submitting the above documents.”

(C) Client for Special  Category (CSC)

Clients of special category (CSC) include the following- i. Non resident clients’  ii. High net-worth clients,

• Trust, Charities, Non-Governmental Organizations (NGOs) and organizations receiving donations

1. Companies having close family shareholdings or beneficial ownership
2. Politically Exposed Persons (PEP) are individuals who are or have  been entrusted with  prominent public  functions in  a  foreign  country, e.g.,  Heads of States  or  of Governments,   senior    politicians,   senior    government/judicial/military   officers, senior  executives of state-owned corporations, important political  party officials, etc. The additional norms applicable to PEP as contained in the  subsequent para  5 of this  circular shall  also  be  applied to  the  accounts of the  family  members or  close relatives of PEPs.
3. Companies offering foreign exchange offerings vii. Clients in high  risk countries where existence  / effectiveness of money laundering controls is suspect, where there is unusual banking secrecy, countries active in narcotics production, countries where corruption  (as  per   Transparency  International  Corruption  Perception  Index)   is highly    prevalent,  countries  against  which   government  sanctions  are   applied, countries reputed to  be any  of the  following – Havens/ sponsors of international terrorism, offshore   financial centers,   tax  havens, countries where fraud is  highly prevalent. While dealing with  clients  in high  risk countries where the existence/effectiveness   of   money  laundering   control    is   suspect, intermediaries apart from  being  guided by the  Financial Action  Task  Force (FATF) statements  that   identify  countries that   do  not  or  insufficiently apply  the  FATF Recommendations, published by the FATF on its website (www.fatf– org),  shall also independently access and consider other  publicly available information.

• Non face to face clients

1. Clients with dubious reputation as per public information available etc. The above   mentioned list is only illustrative and   the intermediary shall exercise independent judgment to ascertain whether any other set of clients shall be classified as CSC or not.

(D) Policy for acceptance of clients

The following safeguards are to be followed while accepting the clients:-

No account is opened in a fictitious / benami name or on an anonymous basis. To ensure this we must insist the client to fill up all the necessary details in the KYC form in our presence and obtain all the necessary documentary evidence in support of the information filled in KYC. We identify the client whether he is debarred entity or not?

We must verify all the documents submitted in support of information filled in the KYC form with the originals and in-person verification should be done by our own staff.  Moreover new client should either be introduced by an existing customer or by the senior official of the company.

In  case  we   have   any   doubt  that   in-complete  / fictitious  information  is submitted by the client, we must  ask for such  additional information so as to satisfy ourselves about  the genuineness of the clients.

We should not continue to do business with such a person and file a suspicious activity report. We should also evaluate whether there is suspicious trading in  the  account and  whether there  is a need  to  freeze  or close the account.

We  should be  careful  while  accepting clients  of special  category like  NRIs, HNIs,  Trust,  Charities, NGOs,  Politically Exposed Persons (PEP), persons of foreign     origin,     companies   having    closed     share holding/ownership, companies dealing in foreign  currency, overseas in high  risk  countries, non face to face clients,  clients  with  dubious background. Current/Former senior high profile politician, Companies offering foreign exchange, etc.) or clients from high-risk countries or  clients  belonging to  countries where corruption/fraud level  is high.  Scrutinize minutely the records/documents pertaining to clients belonging to aforesaid category.

Do not compromise on  submission of mandatory information / documents. Client’s account should be opened only on receipt of mandatory information along with authentic supporting documents as per the regulatory guidelines. Do not  open  the  accounts where the  client  refuses  to provide information / documents and  we  should have  sufficient to  reject  the  client  towards this reluctance.

(E)  Risk based Approach

It  is  recognized that   certain   clients   may  be  of  a  higher or  lower   risk  category depending on  the  circumstances such  as the  client’s background, type  of business relationship or  transaction etc.  As such, the registered intermediaries shall apply each of the client due diligence measures on a risk sensitive basis. The basic principle enshrined in  this  approach is  that   the  registered  intermediaries  shall  adopt  an enhanced  client   due    diligence  process  for   higher  risk   categories  of   clients. Conversely, a simplified client due diligence process may be adopted for lower risk categories of clients.  In line  with  the  risk-based approach, the  type  and  amount of identification information and  documents that  registered intermediaries shall obtain necessarily depend  on  the  risk  category of  a  particular client.  Further, low risk provisions shall not apply when there   are suspicions of ML/FT or when other factors give rise to a belief that the customer does not in fact pose a low risk.

Risk Assessment

We shall  carry  out  risk assessment to identify, assess  and  take effective  measures to mitigate its money laundering and  terrorist financing risk with  respect to its clients, countries  or   geographical  areas,   nature  and   volume  of  transactions,  payment methods used  by  clients,  etc. The  risk  assessment shall  also  take  into  account any country specific information that  is circulated by the Government of India  and  SEBI from  time  to time,  as well  as, the  updated list of individuals and  entities who  are subjected  to  sanction  measures  as  required  under  the  various  United  Nations’ Security         Council         Resolutions                http://www.un.org/sc/committees/ 1267/aq_sanctions_list.shtml    and     http://www.un.org/sc/     committees/1988/ list.html).

The  risk  assessment carried out  shall  consider all  the  relevant risk  factors  before determining the level of overall  risk and  the appropriate level and  type  of mitigation to  be  applied. The  assessment shall  be  documented, updated regularly and  made available to competent authorities and self-regulating bodies,  as and  when required

Factors of risk perception of the client 

Factors of Risk Perception having regard to  Client`s Location ( Registered / Correspondence/ other address)

Particulars – Risk Perception

• Face to Face clients of Agra  – Low Risk
• Face to Face clients of other than Agra – Low Risk
• Client Introduced by existing Face to Face – Clients Low Risk
• Client Introduced by other Existing Clients – Medium Risk
• Direct Clients of Agra – Medium Risk
• Direct Clients of other than Agra – High Risk
• Non- resident Clients – High Risk

Nature of Business Activity, Trading Turnover etc.

-Retail clients (average daily turnover < Rs 1 Crore) – Low Risk

• Retail clients (average daily turnover > Rs. 1 Crore & < Rs.2 Crore – Medium Risk
• HNI Clients (average daily turnover > Rs. 2 Crore – High Risk

Manner of Making Payment

• Regular payment  through  A/c  payee  cheque  from  the  Bank  A/c already mapped with us – Low Risk
• Payment through A/c payee cheque from the Bank A/c other than one already mapped with us – Medium Risk
• Payment through Banker`s Cheque / Demand Draft / Cash – High Risk
• Client of Special Categories – Very High Risk

(C) Suspicious Transaction identification and reporting

Suspicious Transactions

Suspicious transaction means a transaction whether or not made in cash, which  to a person acting  in good  faith  gives  rise to a reasonable ground of suspicious that  it may  involve the proceeds  of  crime;   or  appears  to  be  made  in  circumstance  of  unusual  or  unjustified complexity; or appear to have no economic rationale or bona fide purpose.

1. A) Reasons for Suspicious:

Identity of client

Non-face to face client;

False identification documents;

Clients  in high-risk jurisdiction;

Accounts opened with names very close to other  established business entities;

Identification documents which  could  not be verified within reasonable time;

Receipt back of welcome kit undelivered at the address given  by the client;     Doubt over the real beneficiary of the account;     Suspicious background or links with  criminals.

Multiple Accounts

Unexplained transfers between such  multiple accounts Activity  in Accounts;

Large   number  of  accounts  having  a  common  parameters  as  common  partners  / directors / promoters / address / email  address / telephone numbers introducer or authorized signatory;

Use others different accounts by clients alternatively;

Activity inconsistent with what  be expected from declared business;     Unusual activity  compared to past transactions;     Sudden activity  in dormant accounts.

Nature of Transactions

Source of funds is doubtful;

Unusual or unjustified complexity;

Appears to be case of insider trading;

No economic rationale or bonafied purpose;

Transactions reflect likely market manipulation;

Suspicious off market transaction;

Purchases made on  own  account transferred  to  a  third party through an  off market      transaction through DP account.

Value of Transaction

Value just under the  reporting threshold amount  in  an  apparent  attempt to  avoid reporting;

Inconsistent with the clients apparent financial standing;

Inconsistency in the payment pattern by client;

Block   deal    which    is   not   at   market   price    or   prices    appear  to   be   artificially inflated/deflated;

Large sums  being transferred from overseas for making payments.

Identifying and Reporting  suspicious transaction

The  Principle Officer  for  any  suspicious transaction  will  transaction  filtered out  of  the following filters  in detail.  As the Business  dynamics are very  varied and  complex, defining transaction types  for reporting will not be undertaken at this juncture. Having said  that,  the Principal Officer  will review all the  transactions thrown out  by the filters  and  decides on a case-to case basis to report to FIU with  in stipulated time with complete details.

These  filters  will  be reviewed regularly for any  updations and  modifications to make  the system more robust and effective.

1. Payment for payout to all the clients will be only through cheque. No cash payments to be entertained under any circumstances.
2. All third party cheques to the credit of clients accounts irrespective of the amount.
3. All payment  made either   by  way   of  Demand Draft/Cheque/Money  Transfer/Funds Transfer in  foreign   currencies  irrespective  of  the  In  case  of  DD  it  should be accompanied by the letter of bank in case of some unavoidable situation.
4. To discourage the manipulation relating to the strength, we have started the provision of updating the financial statements of the clients annually and this is the ongoing procedure.

What to Report

The amount of the transaction and the currency in which  it was denominated;

The date on which  the transaction was conducted;

The nature of the transactions;     The parties to the transaction;     The reason of suspicion.

Retention of records

Records pertaining to active clients and staff details collected for recruitment shall be kept safely.  Further company has a policy to retain all records relating to  PMLA provision for at least  a period of 5 years.  We have also retained the statutory and regulatory compliance relating records and co-operate with law enforcement authorities with timely  disclosure of information.

Intermediaries shall  take  appropriate steps  to  evolve  an  internal  mechanism for proper maintenance and  preservation of such  records and  information in a manner that allows  easy and  quick retrieval of data  as and  when requested by the competent authorities. Further, the  records mentioned  in  Rule  3  of  PML  Rules  have  to  be maintained and  preserved for  a period of ten  years  from  the  date  of transactions between the client and  intermediary.

As stated in sub-section 5.5, intermediaries are required to formulate and  implement the  CIP containing the  requirements as laid  down in Rule  9 of the  PML Rules  and such   other   additional  requirements  that   it  considers  appropriate.  The   records evidencing the identity of its clients and beneficial owners as well as account files and business correspondence shall be maintained and preserved for a period of five years after the business relationship between a client and intermediary has ended or the account has been closed, whichever is later.”

Thus the following document retention terms shall be observed: –

• All necessary records on transactions, both domestic and  international,  shall   be maintained  at   least   for   the  minimum  period prescribed under the  relevant Act and  Rules  (PMLA  and  rules  framed thereunder   as  well  SEBI Act)    and    other legislations,  Regulations  or  exchange bye-laws or circulars.
• Records on  client  identification (e.g. copies  or records of official   identification documents like  passports, identity cards,  driving  licenses  or  similar  documents), account files and business correspondence shall also be kept for the same period.

In  situations where the  records relate  to  on-going investigations  or  transactions which  have  been  the  subject  of a   suspicious transaction reporting, they  shall  be retained until  it is confirmed that the case has been closed.

List of Designated Individuals/Entities

An  updated list  of individuals and  entities which  are  subject  to  various sanction measures such  as  freezing of assets/accounts, denial   of financial services  etc.,  as approved  by  the     Security   Council   Committee established pursuant  to  various United Nations’ Security    Council  Resolutions (UNSCRs)  can   be     accessed   at  its website at http://www.un.org/sc/committees/1267/consolist.shtml. Registered intermediaries are directed to ensure that accounts are not opened in the name of anyone whose    name    appears in said list. Registered intermediaries   shall continuously scan all existing accounts to ensure that no account is held by or linked to  any  of the  entities or  individuals included in  the  list.  Full details   of accounts bearing   resemblance with    any    of   the   individuals/entities   in   the   list   shall immediately be intimated to SEBI and FIU-IND.

Procedure for freezing of funds, financial assets  or economic resources  or relatedservices

As  per  section   51A,  of  the  Unlawful  Activities (Prevention)  Act,  1967  (UAPA), relating to  the  purpose of  prevention of,  and   for  coping   with  terrorist activities was  brought into  effect  through UAPA  Amendment Act,  2008. In this  regard, the Central  Government  has  issued  an  Order dated  August 27,  2009  detailing  the procedure for the implementation of Section 51A of the UAPA.    Under the aforementioned Section,  the  Central Government  is empowered to freeze,  seize  or attach  funds and  other  financial assets  or economic  resources  held   by,  on   behalf of,  or  at  the   direction  of  the individuals or entities listed  in the Schedule to  the Order, or any other  person  engaged in  or  suspected to  be  engaged in  terrorism. The Government is also further empowered to prohibit any individual or entity  from making  any   funds,  financial  assets   or   economic  resources  or   related  services available for the  benefit  of the  individuals or entities listed  in the  Schedule to the Order or any other  person engaged in or suspected to be engaged in terrorism.  The obligations to be followed by intermediaries to ensure the effective  and  expeditious implementation of   said  Order has  been    issued   vide    SEBI   Circular   ref.    no: ISD/AML/CIR-2/2009    dated October  23, 2009, which  needs  to be complied with scrupulously.

Information to be maintained

Company will maintain and   preserve the following information in respect of transactions referred to in Rule 3 of PMLA Rules for the period of 10 years.

1. Contract Note;
2. Client Registration Forms;

• Nature of the transactions;

1. Date on which the transaction was conducted;
2. Amount of the transaction and the currency in which it denominated; VI. Parties to the transaction.

Monitoring of transactions

We have initiated to regular monitoring of transactions for ensuring effectiveness of the AML procedures. In  this  respect  we  have   an  understanding  of  the  normal activity  of the client so that it can identify deviations in transactions / activities.

We shall pay special attention to all complex, unusually large transactions / patterns which appear to have no economic purpose. The intermediary may  specify  internal threshold  limits   for  each   class  of  client   accounts  and   pay   special   attention  to transactions which   exceeds   these  limits.  The background including all documents/office records /memorandums/clarifications sought pertaining to such transactions and purpose thereof shall also be examined carefully and findings shall be recorded in writing. Further such  findings, records and  related documents shall be  made available to  auditors and   also  to  SEBI/stock  exchanges/FIUIND/other relevant  Authorities, during  audit,  inspection or  as  and   when  required.  These records are required to be preserved for ten years as is required under the PMLA.

We shall ensure a record of the transactions is preserved and  maintained in terms  of

Section  12 of the  PMLA  and  that  transactions of a suspicious nature or  any  other transactions notified under Section  12 of the  Act are  reported to the  Director, FIU- IND. Suspicious transactions shall   also   be   regularly reported to the higher authorities within the intermediary.

Further, the compliance cell of the intermediary shall randomly examine a selection of transactions undertaken by clients to comment on their nature i.e. whether they are in the nature of suspicious transactions or not.

Hiring of Employees

We  shall  have  adequate screening procedures in  place  to  ensure high  standards when hiring employees, having regard to the risk of money laundering and  terrorist financing and  the  size  of the  business, we  ensure that  all the  employees taking  up such key positions are suitable and  competent to perform their duties. The Company HR  is  instructed  to  cross   check   all  the   references  and   should  take   adequate safeguards to establish the authenticity and  genuineness of the persons before recruiting. The department obtains the adequate documents for verification thereof.

Record Keeping

We shall  ensure compliance with  the record keeping requirements contained in the SEBI Act,  1992, Rules  and  Regulations made  there-under, PMLA  as well  as  other relevant legislation, Rules,  Regulations, Exchange Bye-laws  and  Circulars. We shall maintain such records as are sufficient to permit reconstruction of individual transactions (including the amounts and types of currencies involved, if any) so as to provide, if necessary, evidence for prosecution of criminal behavior.

We Shall there be any suspected drug related or other laundered money or terrorist property, the competent investigating authorities would need to trace through the audit trail for reconstructing a financial profile of the suspect account. To enable  this reconstruction, registered intermediaries shall  retain  the  following information for the  accounts of their  clients  in  order to  maintain a satisfactory audit trail:  (a) the beneficial  owner of the  account;  (b) the  volume of the  funds flowing through the account;  and (c) for selected  transactions:-

• the origin of the funds;
• the form  in  which  the  funds were  offered  or  withdrawn, e.g.  cheques, demand drafts
• the identity of the person undertaking the transaction;
• the destination of the funds;
• the form of instruction and authority.

We shall ensure that all client and transaction records and information are available on a timely basis to the competent investigating authorities. Where required by the investigating authority, they shall retain certain records, e.g.  client  identification, account files,  and  business correspondence, for  periods which   may  exceed  those required under the  SEBI Act,  Rules  and  Regulations framed  there-under  PMLA, other  relevant legislations, Rules and  Regulations or Exchange bye-laws or circulars.

6.5 More specifically, all the intermediaries shall put  in place a system  of maintaining proper record of transactions prescribed under Rule  3 of PML Rules  as mentioned below:-

• all cash transactions of the value of more  than  rupees ten lakh or its equivalent in foreign  currency;
• all series of cash transactions integrally connected to each other which  have  been valued below  rupees ten lakh or its equivalent in foreign  currency where such series of transactions have  taken  place  within a month and  the  aggregate value  of such transactions exceeds  rupees ten lakh;
• all cash transactions where forged or counterfeit currency notes  or bank  notes have  been  used  as genuine and  where any  forgery of a valuable security has  taken place;
• all suspicious transactions whether or not made in  and  by way  of as mentioned in the Rules.

Employees’ Training

Company adopted an ongoing employee training program so that the members of the staff are adequately trained in AML procedures. Training requirements have specific    focuses    for   frontline   staff,   back   office   staff,   compliance   staff,   risk management staff and staff dealing with new customers. It is crucial  that  all those concerned fully  understand the  rationale behind these  guidelines, obligations and requirements, implement them  consistently and  are  sensitive to  the  risks  of their systems being  misused by unscrupulous elements. The said training programme is being conducted through personal meeting/presentation.

Investors  Education

Implementation of AML measures requires back office and trading staff to demand certain information from investors which may be of personal nature or which have hitherto never been called for. Such information can include documents evidencing source of funds/income tax returns/bank records etc. This  can  sometimes lead  to raising of  questions by  the  customer with  regard to  the  motive and  purpose of collecting such information. There is, therefore, a need  for the back office and trading staff  to  sensitize their  customers about  these  requirements as the  ones  emanating from  AML  framework. The back office and trading staff should prepare specific literature/ pamphlets etc. so as to educate the customer of the objectives of the AML programme.

Reporting  to FIU

In terms of the PMLA rules, Intermediaries are required to report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit- India (FIU-IND)

1. Cash Transaction Reports: The Prevention of Money-laundering Act, 2002, and rule there under require every intermediary, to furnish to FIU-IND information relating to:

All cash transactions of the value of more than rupees ten lakhs or its equivalent in foreign currency;

All series of cash transactions integrally connected to each other which have been valued below rupees ten lakhs or its equivalent in foreign currency where such series of transactions have taken place within a month;

The cash transaction report (CTR) (wherever applicable) for each month should be submitted to FIU-IND by 15th of the succeeding month.

All are requested not to accept cash from the clients whether against obligations or as margin for purchase of commodities or otherwise. All payments shall be received from the clients strictly by account payee crossed cheques drawn in favour of Raghunandan Capital Private Limited.

1. Suspicious Transaction Reports:

All are requested to analyze and furnish details of suspicious transactions, whether or not made in cash. It should be ensured that there is no undue delay in analysis and arriving at a conclusion.

The intermediary shall furnish to FIU-IND information of all suspicious transactions whether or not made in cash.

The Principal Officer should record his reasons for treating any transaction or a series of transactions as suspicious. It should be ensured that there is no undue delay in arriving at such a conclusion. The Principal Officer will be responsible for timely submission of CTR and STR to FIU-IND concerning also the Red flags as indicated by FIU for generation of alerts and identification of suspicious transaction. Utmost confidentiality should be maintained in filing of CTR and STR to FIU-IND. The reports may be transmitted by speed/registered post/e-mail/fax at the notified address.

• Counterfeit Currency Reports:

All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine or where any forgery of a valuable security or a document has taken place facilitating the transactions may reported in Counterfeit Currency Reports (CCR).

Prevention of Money Laundering (Maintenance of Records) Rules, 2005 

Prevention of Money Laundering (Maintenance of Records) Rules, 2005 has been amended as per the gazette notification dated June 1, 2017:-

1. Where the client has not submitted Aadhaar number at the time of commencement of account based relationship with the reporting entity, as per the PMLA requirement, then he/ it shall submit the same within 6 months of commencement of account based relationship with the reporting entity.
2. Similarly, where the client is already having an account based relationship with reporting entities, prior to the date of notification, and have not submitted Aadhaar number, as per the PMLA requirement, to the reporting entity, then he/ it shall submit the same by December 31, 2017
3. In case of failure to submit the documents within the aforesaid time limit, the account shall cease to be operational till the time Aadhaar number is submitted by the client.

Review of policy

The   aforesaid AML   policy   is   reviewed periodically to   meet   the   compliance requirements of PMLA 2002. The principal officer is the authority to give directions to concern for addition, changes, modifications etc. as directed by SEBI/FIU-IND.

Above said policies are reviewed by us on regular basis to keep it updated as per the various amendments in the PMLA rules.

In case any further information /clarification is required in this regard, the Principal Office may be contacted as follows :-

Mr. Rahil Uddin

Address: 26/257 B, Near Ashish Palace,

SultanGanj, Agra – 282004

Tel : 0562-4266600 | Fax : 0562-2526550

Email: askus@rmoneyindia.com

For Raghunandan Capital Private Limited 

Sd/- Director

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Raghunandan Capital (P) Ltd. has designed following RMS Policy for trading in Equity / Derivatives / Currency Derivatives Segments. The Policy shall be applicable to all the clients trading through RCPL in Equity / Derivatives / Currency Derivatives Segments of NSE / BSE / MCX-SX / USE as the case may be.

1. 1. COMPUTATION OF FREE BALANCE :The Company has the system to provide trading limits based on the Total Available Margin and the same shall be computed as under :The Company has the system to provide trading limits based on the Total Available Margin and the same shall be computed as under :

 TRADING LIMITS 

2. MARGIN CALLS : 

First Margin Call will be given as soon as the MTM Loss reaches 50 % of the Total Available Margin and client will be asked to submit fresh margin or reduce the positions and the client will be in square off mode until he provides fresh margin or his MTM comes below 40% of Free Balance.

Second Margin Call Call will be given when MTM Loss exceeds 65% of Available Clear Balance and if client does not bring in fresh margin or reduces his exposure himself before MTM reaches 80% of clear balance his positions will be squared off without further notice.

For this purpose calls to be made on registered Mobile No / emails sent to registered email addresses/ fax sent of registered fax no shall be treated as valid delivery of margin calls.

In case of Square off of the positions best efforts to be made to leave open positions to the extent that could ordinarily be carried forward as per Exchange norms on the available free balance after setting aside the MTM Loss for the day till 3.00 p.m..

In case of Square off of the positions best efforts to be made to leave open positions to the extent that could ordinarily be carried forward as per Exchange norms on the available free balance after setting aside the MTM Loss for the day till 3.00 p.m..

While closing out, the positions with highest margin/highest MTM Loss will be closed out first.

For Margin Tag the time limit will be 3.15 p.m. for squaring off outstanding positions and after 3.15 p.m. Square Off mode will be activated and no fresh orders will be allowed in margin tag.

3. All the cheques once committed for carry forward positions / intra day limits must be deposited and cleared irrespective of margin requirement during subsequent days.

RMS department shall maintain the list of all the fake cheque commitments and ensure due clearance of the same

4. In equity Segment all debits must be cleared off latest by T+2, else RMS will sell deliveries on T+3 by 02.30 p.m. to regularize the account.

5. All the new listings in T 2 T settlement will be disabled for selling by default by the RMS department and only the clients who transfer their shares in advance to the pool account will be able to sell on the listing day.

6. Defaulter List shall be prepared and bought to the notice of Management on monthly basis. The Management reserves the right to remove any person form defaulter list in consultation with concerned VPs.

7. Payment control Report for debit recovery from the clients is made on daily basis and follow-up for the payment on regular basis done by RMS department.

Internal Control Policy

A) Client Registration, Documents maintenance:

Account opening Process and documents maintenance is taken care of in house by a separate account opening department centrally. The process is maintained in such a manner that from verification to enabling the UCC upload, different persons are involved and responsible for each step so that the concept of maker checker is effectively taken care of. Proper MIS is sent for the different steps so that proper control and checks are exercised. Forms received at our various locations are received at centralized account opening  department after the basic checking of the account opening kit and in person-verification of documents/proofs received with its original. After opening the code, welcome kit & copy of documents executed is sent by the post to the address given in the account opening form along with all the concerned  telephone numbers  and email id’s where the client can make his queries/complaints along with the details entered in the Client Master. After opening of accounts we also do periodic review of the client’s & obtain their financial & other details. Particulars of client’s or change in client master details of the client’s are done as per the specific request of clients after receiving documentary proofs if required.   All the documents are kept in such a manner so that it can be retrieved whenever required after opening of the account. Our marketing personals  are provided regular  training  to  make  them  update  about  the various exchange norms so that they can provide appropriate information to prospective client’s while offering services related to financial markets. We ensure that promotional schemes must adhere  the  exchange  norms  in  this regard.

B) Closure of Client Accounts/Dormant Account

Accounts are closed on request of the client or after giving intimation from our side to the client. In case of client request accounts are closed only after verification all the documents & settlement of all the dues & securities etc.

For closure of client account, we receipt the letter from client, who want to close his/her client account and give a receipt to the client. We make this client code inactive in our back office, so that no trade can be done/punched in his/her client code. For Transfer of client from one branch to another branch, we have change in our back office. A daily file is generated from our back office to verify whether any trade has been done in any code which is dormant in nature & if any such case is found then it should be verified from the concerned clients to ensure that said trade is done by the respective client only.

C) Order Receipt and Execution

Orders are received from the clients telephonically or personally and are executed as per the instructions of the clients. Dealers receiving the telephonic orders make necessary verification before executing the orders. At most of the locations, the telephone lines are recorded for which logs are maintained for a period of 1 month.

There is system of trade confirmation via SMS and Telephonically on the numbers given by the clients  in  the Account  opening form. No discretionary powers are exercised at any location to execute client orders. Controls like executing orders by personal visits and voice confirmation by the dealers are adopted for receipt of order from respective client only.

D) Sending Contract Notes, Daily Margin statement, Quarterly Statement of Accounts to clients:

All the Contact notes alongwith daily margin statement for the trades executed are centrally sent by email  on daily basis within 24 hours trades executed to our clients. Log file are maintained for the contract notes sent to the clients. The quarterly statements are dispatch within the stipulated time by email. All client are provided access to the web based back office where all the reports including contract notes, settlement obligation, daily margin reports ,etc are provided to the clients.

E) Collection of pay in, margin, limits setting for exposures & turnover for clients, terminals, branches & Authorised Person (AP)

We take the clients payin only by first party cheque which is self authorized by the client. Similarly the upfront margin for Future and options is taken in the form of First party chq (Self authorized) and pledged stocks (haircut applicable as per exchange).The premium for options is taken only through cheque and MTM is also settled by cheques only.

Clients can deposit the cheques at our local branches & we provides its credit to the clients after receiving scanned copy of the cheques so that third party transactions can’t be made

The limits and exposure is provided as per the clients debit and credit positions, along with stocks lying with  us, margin requirement for the open positions in  f&o segment, MTM check and ageing report is also taken in consideration. Payments are made to clients as per the request of client in case of running case and in any other case payment is to clients through cheques in compliance of exchange norms.

F) Squareoff of positions/Liquidation of securities without consent of clients

The Clients are informed of any increase in margin, or any increase in MTM losses beyond their collaterals through emails, phones and sending sms to the clients mobile number. We provide opportunities to the clients to bring in adequate  margin to such  extent  so that  our position  does not  remain uncovered. If payment is not received despite reminders then we square off the positions after giving prior intimation to the clients and the details is communicated by telephone, SMS or email.

G)Transfer of Trades

The trade is not transfer to one client to another client account. If in rare case if any error  is occurred from dealer,  then  we take  the letter from both the client and modify the same within the prescribed time in exchange online.

H) Policy of Internal Shortage

We have followed the policy prescribed by the Exchange in  case of internal shortage

I) Investor Redressal Mechanism

Investor Satisfaction being of utmost importance, investor redressal mechanism is the most important activity for which necessary mechanism and systems are in place. All the investor grievances are monitored and redressed by the Compliance Officer of the Company who reports directly to the Board of Directors and this essentially takes care of the necessary escalation in case of any long pending and serious compliant,  otherwise the same are taken care of by the Compliance Officer with the support of the Compliance team. The clients can  email  their grievances  on the  email  ID  askus@rmoneyindia.com  which  is displayed  on our website and  the same also mentioned  on the contract notes and other correspondence if any sent to the client from time to time. All the mails received are duly monitored  and redressed  by the Compliance  Officer. The  register  of  grievances  is  centrally maintained  for  better  control  and Monitoring, thus the grievances received in writing, mail, verbally, etc. are centrally monitored and redressed and recorded with all the necessary steps taken for redressal of the same. Proper analysis is undertaken to analyze the nature of complaints received, pattern of complaints and concentration if any at a particular location, so that every effort is taken to remove the root cause of grievance by the client. Periodic visits  and inspections are undertaken for the branches and sub brokers to get the feedback of clients on the issues like receipt of contract notes, trade confirmation, SOA & margin statements etc. Depending on the feedback received necessary corrective steps are introduced into the  system.  For  ensuring  that  the  funds  received  from the  particular clients are properly accounted for, scanned copy of all the cheques collected at various locations is received at the Head Office where centralized accounting is maintained, by which it is ensured that the cheques are credited to the account of the correct client and also from the particular accounts mentioned in the client  account  master  in  the Back office software  maintained centrally.  No other separate software is maintained for maintaining client account details.

Thus every attempt is made to redress the grievance/problems of the clients and introduce systematic changes into the processes so that such instances are avoided.

J) Allotment, Surrender of trading terminals, Opening & Closing of Branches.

1. Our exposure and limit mechanism is automatic and every client gets limits as per their funds and stocks. Moreover we keep a watch on the trading activities of each and every client and the dealer id’s. In case we find  any discrepancy  with  the  norms  and  compliances  we  take immediate actions which depends on case to case basis. We ensure that only exchange approved software are used. In case if any client wants trade in some other locations we take NOC from those clients and map the id where he wishes to trade. Information pertaining to allotment & surrender of trading terminals are submitted to the exchange through the software provided by the exchange in this regard. Our Risk Management &  Compliance  keeps records  that  terminals  provided to Braches  &  Sub-Brokers  could  not  be used for  unauthorized/  illegal purpose.
2. Opening & Closing of branches/ sub broker offices Branch is opened at a particular location after  the feasibility s t u d y is positive. All the steps decided in the opening procedure from compliance perspective   are taken   care  by  the   Compliance   Department.   AP registration is also taken care by the Compliance Department. In case of surrender of sub broker ship, the procedure prescribed by the Exchange is followed.  In case of closure, as per the procedure the financial ledger confirmation is taken from the clients and all the clients are informed that in case of any disputes they have 1 month’s  time  to come out with discrepancies, if any.
3. All the requests for allotment and surrender of trading terminals are processed centrally from the Head Office. After due verification, the Co-ordination Department which is continuously in touch with the branches and sub brokers forwards the details to the Compliance Department for the submission of information to the Exchange. Thus the verification of information in respect of username, user id, location, etc. is done at 2 points to ensure submission of the correct information.

K) Branch & AP Audits

We have designated a Compliance team which is headed by the Compliance Officer for periodic inspection of Branch & Sub-Brokers Audit on periodic basis. We ensure that all the areas as per the exchange norms are covered under the inspection. After the inspection a report is provided to concerned office with findings of the inspection along with the suggestions for better compliance. We also ensure that Notice Boar & SEBI registration certificates are displayed at the branch/ AP office. We have appointed auditor  for conducting the  internal  audits  as  per the exchange norms.  Findings & suggestions of the Internal Auditors are referred to audit committee which is designated to comply with the findings of the internal & rectify the discrepancies if any found.

For Raghunandan Capital Private Limited 

  Sd/- Director

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Client Code Modification Policy

1. The modification to the client code is to be done only in exceptional cases and not as a routine one.
2. The    reason   for  modification has  to be  ascertained  and   analyzed  and genuineness  is to be  established and  also it’s impact on the clients  should be Studied  before the modification. If voice recording is in practice, the same is being studied.
3. Normally as a principle, other than for punching errors, no modification to the client codes is allowed.
4. Therefore it is imperative that  the issue should be reported to the senior level Manager/ Director and only  with his approval, the modification should be carried  after  being satisfied  that  it is  genuine,  the same is required to be done to protect the interests of the client.
5. Hence the facility to modify the client codes should be available only at the Corporate Manager level and should not be given to the    branches/ franchise/sub-brokers.
6. Training  program should be conducted  to all  the Dealers  and  they should be   explained  how code  modifications can   be  misused  and   what  steps Should   be taken  to avoid the same. It also should be explained that code modifications should not be encouraged to the clients except for cases like ‘punching errors’/’typing  errors’.
7. A register   is to  be  maintained for recording all   the code modifications with details like  error  code,  correct  code,  scrip  name   quantity, client name,  the name   of  the dealer  who punched  the code, the explanation of the  dealer/ Branch  Manager,  the  ‘analysis / study’ of  the    authorised  Manager and his approval/disapproval  for modification.
8. The company shall levy a penalty for any client code modification not covered in above mentioned cases:-

Where ‘a’ = Value (Turnover) of non-institutional trades where client codes have been modified by the Company in a segment during a month.

‘b’ = Value (Turnover) of non-institutional trades of the company on the segment during the month.

1. The client code which are classified as “Error Accounts” shall be                disclosed to the Exchange a the time of uploading the UCC.
2. The genuine code shall be modified after the prior approval of the            Compliance Officer of the Company. Any trade denied for            modification by the Compliance Officer shall not be modified. 

For Raghunandan Capital Private Limited 

  Sd/-Director

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Inactive/Dormant Account Policy

Objective

The  objective  of  the  policy is  to  appropriately  deal  with the  Inactive/dormant clients, where clients have not traded  for one year.

The policy is  also  applicable  for accounts  which have been marked inactive on account of  Rules, Bye  laws, circulars and guidelines issued by  SEBI, Exchanges and Internal Risk Management Policies.

Procedure to handle Inactive/dormant accounts:

If there is no transaction (buy/sell) entered into by the account holder for twelve months, the account will be marked as “INACTIVE/DORMANT”. 

All   the accounts marked as “INACTIVE/DORMANT”   needs to be   monitored carefully in order to avoid unauthorized transactions in the account. If the client wants to make the account “ACTIVE” after twelve months or after providing the required documents supporting the financial status, the client needs to submit a request to reactivate his/her account. In case there is any change in the information such as; address,   mobile  number,  email  ID, bank/demat  account,  financial  disclosure provided in KYC at the time of registration as client, the same has to be  submitted along with the request. After proper  verification  of  the updated / revised details and  approval  from the compliance  officer / or concerned department in-charge of registration of  clients, the account can be  made “ACTIVE”  and transaction can take  place.  Process for reactivation of Inactive /dormant account which are inactive for twelve months.

The Client can follow any of the below processes

1. Call the customer care center or authorized person identifying  himself   and request  for  activation   of  account  for  placing  orders/  transacting  in  the account, or
2. Client can give the duly signed request in writing in the offices of trading member or authorized person along with documents such as Address  Proof

– such as Aadhar Card, Electricity Bill Passport Copy. Identity Proof such as Aadhar Card, Passport Copy, Pan Card and financial Information  required for trading  in  derivative  segment.  The Client may also courier/post the same for activation of account, or

• Client can also send an email from registered mail id for reactivation request.

Review Policy

This policy may be reviewed as and when there are any changes introduced by any statutory authority or as and when it is found necessary to change on account of business needs and Risk Management policy.

The policy may be reviewed by the Compliance Officer/authorized person and place the changes in the policy.

Policy communication

A copy of this policy shall be made available to all the relevant staff/persons such as Compliance officer/department in-charge of registration of clients and sub- broker /authorized persons.

For Raghunandan Capital Private Limited 

  Sd/-Director

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INTERNAL POLICY 

ON 

APPLICABILITY 

OF 

NISM SERIES VII-SORM CERTIFICATION

INTRODUCTION

SEBI notification no. LAD-NRO/GN/2010-11/21/29390 published in the Gazette of India on December 10, 2010 and the Exchange circular NSE/INSP/16536    dated    December    15,    2010,    Exchange     circular NSE/INSP/27495 September 2, 2014, persons associated with a registered stockbroker/trading member/clearing member who are involved in, or deal with in specified functioned functions are required to have a valid NISM Series VII Certification.

Raghunandan Capital Private Limited (refereed herein as “Raghunandan”)has internal policy on applicability of NISM series VII-SORM certification

OBJECTIVES

Raghunandan conducts its business to ensure to have Internal control or risk management, redressal of investor grievances, activities having a bearing on operational risk and dealing with assets or funds of investors or clients.

APPLICABILITY 

Raghunandan enforce the above circular in the following areas/ activities for the better/ effective management:-

Internal control or risk management

1. Inwarding of collateral’s/cheques
2. Person performing maker entries
3. Maker entry in the database
4. Photocopying, printouts, scanning of documents
5. Preparing of MIS
6. Sending of letters/reports  to clients, Exchanges, SEBI
7. Attending calls, etc.

Redressal of investor grievances

1. Inwarding of complaints,
2. Seeking documents from clients
3. Person performing maker entries
4. Maker entry in the database
5. Photocopying, printouts, scanning of documents
6. Preparing of MIS
7. Sending of letters/reports to clients, Exchanges, SEBI Updation, data entry, uploading on SCORES.
8. Attending calls, etc.

Activities having a bearing on operational risk and dealing with assets or funds of investors or clients

1. Person performing maker entries
2. Maker entry in the database
3. Preparing MIS
4. Generating reports, Files
5. Photocopying, printouts, scanning of documents
6. Dispatching documents to clients
7. Sending of letters/reports  to clients, Exchanges, SEBI 
8. Attending calls, etc.

For Raghunandan Capital Private Limited  

  Sd/- Director

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Policy on

Code of Conduct &

Controls relating to

Unauthenticated News

Circulation

Objectives

To protect investors from and to stop unauthenticated news circulation by the Employees / Staffs or other dealing person of Raghunandan Capital Private Limited

Regulation

As per the code of conduct for Stock Broker in SEBI (Stock Brokers and Sub‐brokers) Regulations, 1992 and SEBI circular CIR/ISD/1/2011 dated March 23, 2011, all SEBI registered market intermediaries are required to have proper internal codes of conduct to obstruct the market  news  circulation  through  blogs/chat  forums/email  by  employees without adequate caution may cause considerable damage to the normal functioning and behavior of the market and distort the mechanisms thereof.

Therefore all the employees of Raghunandan Capital Private Limited should follow internal codes of conduct and controls.  Employees/staff etc.  working  in the  office  will  not  encourage  or circulate rumours or unverified information obtained from the client, industry and trade or any other sources without verification.

Implementation of code of Conduct

In this regard, Raghunandan Capital Private Limited implements the  codes  of  conduct  for  the various modes of communication. Company Directors/ Officers / Employees/ Staff etc.

are prohibited from:-

1. Circulating rumors or unverified information obtained from clients, industry, any trade or any other sources without verification.

• Circulation   of unauthenticated   news   related   to various   Scripts   in blogs/chat forums/e-mail, social networking sites etc.

• Forwarding any market related news received in their official mail/personal mail/blog except after the same has been seen and approved by the Compliance Officer. All the reporting with regard to violation of the same shall be done to the designated Compliance Officer.

• Circulation of rumors or unverified information obtained from client, industry, any trade or other sources without verification.

• Access to Blogs/chat forums/messenger sites etc. has been restricted by   

    Raghunandan Capital Private Limited and is not allowed.

ACCESS CONTROL

There will be no access to chat forums/ Messenger sites to Employees/ staff excepts senior officials including Directors, Compliance Officer. All the logs of such sites shall be treated as records and are maintained by the IT deptt. Any information or market related news received by staff in official mail or their personal mail should be forwarded after seen and approved by the Compliance officer.

If an employee violated the provisions contained in SEBI Act/Rules/Regulations etc. and shall be liable for disciplinary action/ strict actions.

Where  the  Client  has  any  grievances,  he  should  promptly  notify  the  same  to  our Compliance   Officer   in  writing,   mentioning   sufficient   details   along   with  supporting documents to e-mail ID of the Compliance Officer   and the grievances email ID. The complaint shall be analyzed and redressed and replied to the client within 7 days/ sufficient time period from the date of the complaint with the resolution of the complaint.

For Raghunandan Capital Private Limited 

  Sd/- Director

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Policy on Conflict of Interests

Introduction

SEBI vide its circular no. CIR/MIRSD/5/2013 dated August 27, 2013 issued a General Guidelines for dealing with Conflicts of Interest of Intermediaries, Recognized Stock Exchanges, Recognized Clearing Corporations, Depositories and their Associated Persons in Securities Market. SEBI decided to put in place comprehensive guidelines to collectively cover such entities and their associated persons, for elimination / avoidance of their conflict of interest and educating the Associated Persons as defined in Securities and Exchange Board of India.

SEBI guidelines intends Intermediaries and their Associated Persons to comply with the following –

• high standards of integrity in the conduct of business;

• fair treatment of clients and no discrimination amongst them;

• not to deal in securities while in possession of material non published information;

• not to communicate the material non published information

• not to manipulate the demand for, or supply of, or to influence prices of, securities.

• not to have an incentive structure that encourages sale of products not suiting the risk profile  of the clients;

• not to share  client information for the personal interest;

• avoidance of conflict of personal interest with the client and primacy of clients’ interest;

• appropriate disclosure to the clients of possible source  or potential areas of conflict of interest;
• reducing the opportunities for conflict through prescriptive measures;

• appropriate restrictions on transactions in securities while handling a mandate of issuer  or client;

2. Policies and Internal Procedures to Identify and avoid or to deal or manage actual or potential  Conflict  of Interest

In order to strive for achieving management of conflict of interests, Raghunandan Capital Private Limited shall endeavor-

• To promote high standards of integrity in the conduct of business of Raghunandan Capital Private Limited.

• To ensure fairness of dealing with clients

• To guide for identification, elimination or management of conflict of interest situations

• To provide a mechanism for review and assessment of the policy(ies)  on  conflict  of interests

The  conflict  of interest policy  aims  to  ensure that  the  Company’s clients  are  treated fairly  and  at  the  highest level  of integrity and  that  their  interests are  protected at  all times. It also aims to identify conflicts of interest between:-

• The Company and a Client

• Relevant Person and a Client

• A Company of the Group and a Client

• Two  or  more  Clients  of the  Company in  the  course  of providing services  to  these Clients

• A Company service provider and a Client

In addition it aims to prevent conflicts of interest from adversely affecting the interest of its Client.

Conflicts of Interest Policy sets out how:-

• The Company will identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to our Clients’ interests;

• The Company has established appropriate mechanisms and systems to manage those conflicts;

• The Company maintains systems designed to prevent damage to our Clients’ interests through identified conflicts.

 “Conflict  of Interest”

Conflicts of Interest can be defined in many ways, including any situation in which an individual or else is in a position to exploit a professional or official capacity in some way for their personal or corporate benefit. A conflict of interest is a manifestation of the moral hazard problem, particularly when a financial institution provides multiple services   and   the   potentially competing interests of those   services   may   lead to a concealment of information or dissemination of misleading information. A conflict of interest exists when a party to a transaction could potentially make gain from taking actions that are detrimental to the other party in the transaction.

Identification of Conflicts of Interests

The Company shall take adequate steps to identify conflicts of interest. In identifying conflicts of interest, the Company will take into account situations where the Company or an employee or a Relevant Person:

• Is likely to make a financial gain, or avoid a financial loss, at the expense of the Client;

• Has  an interest in the outcome of a service  provided to the Client  or of a transaction carried out  on  behalf  of the  Client,  which  is distinct from  the  Client’s  interest in that outcome;

• Has a financial or other incentive to favour the interest of one Client over another;

• Carries out the same business as the Client; or

• Receives  from  a person other  than  a Client  an  inducement in  relation to  a service provided to a Client,  in the form  of monies, goods  or services,  other  than  the standard commission or fee for that service.

 Potential  Conflict  of Interest

In order to avoid, manage or deal with conflict of interest with the intermediary or the Associated Persons, it is important to identify the possible areas  of conflict  of interest. Raghunandan Capital Private Limited lists out the following potential conflict of interest that may affect the company:-

1. Directorships or other employment;

1. Interests in business enterprises or professional practices;

1. Share ownership;
2. Beneficial interests in trusts;

• Personal Account Trading;

• Professional associations or relationships with other organizations;

• Personal associations with other groups or organizations, or family relationships;

• Commission;

• Where the company carries on the same business as a client;

• Where  the company designs, markets or recommends a product or service  without properly considering all  our  other  products and  services  and  the  interest of all  our clients;

• Where  the  company has  a  financial or  other  incentive to  favour the  interest  of another client or group of clients over the interests of a client;

• Where  the company has an interest in the outcome of a service  provided to, or of a transaction carried out  on behalf  of, a client  which  is distinct from  that  client’s interest in that outcome;

• Where the company is likely to make a financial gain or avoid a financial loss at the expense of a client; and

• Where  the company receives,  or will receive, from the person other  than  a client an inducement in  relation to  the  service  provided to  that  client  in  the  form  of monies, goods  or services,  other  than  the standard commission or fee for that service;

Measures to avoid or to deal or manage actual or potential Conflict  of Interests(COI)

Conflict of interest should arise, it needs   to be managed promptly and fairly.  The Company puts in place following arrangements to ensure that:

1. There is a clear distinction between the different departments’ operations;

1. No single person will gather conflicting information, thus counterfeiting or hiding information from investors is minimized;

1. The Company’s employees are prohibited from investing in a financial instrument for which they have access to non-public or confidential information; iv. Transactions by the Company’s employees are neither performed nor executed by themselves.

• Employees sign  a  contract of  employment  including  confidentiality clauses.   No associated person may disclose  inside  information to others,  except  disclosures made in accordance with  the  Company’s policies  and  procedures, to other  Company personnel or persons outside the  Company who  have  a valid  business reason for receiving such information;

• Each department will control the flow of information where, otherwise, the risk of conflict of interest may harm the interest of a Client;

• Relevant information is recorded promptly in a secure   environment to enable identification and management of conflicts of interests;

• Adequate records are maintained of the services and activities of the Company where a conflict of interest has been identified;

1. In certain jurisdictions appropriate disclosure may be made to the Client in a clear, fair and not misleading manner to enable the Client to make an informed decision;

• There is a periodic review of the adequacy of the Company’s systems and controls.

Information barriers

The  Company  respects the  confidentiality  of  information  it  receives   regarding  its Clients  and  operates a “Need to Know”  approach and  complies with  all applicable laws in  respect of the  handling of that  information. Access  to  confidential information  is restricted to those  who  have  a proper requirement for the  information consistent with the  legitimate interest of  a  Client  of  the  Company. The Company operates internal organizational arrangements to avoid conflicts of interest by controlling, managing or restricting, as deemed appropriate, the flow of confidential information between different areas  of business or within a specific division or department.

 Disclosure to clients  of possible source or potential areas of conflict  of interest(COI):

i. Raghunandan Capital Private Limited or its associated persons should, in writing,

disclose  to a client  any  COI in respect of that client including –

1. Measures taken to avoid or mitigate the conflict;
2. Any ownership interest or financial interest that the provider or representative may be or become eligible for;
3. The nature of the relationship or arrangements with a third party that gives rise to a COI in sufficient detail to enable the client to understand the exact nature of the COI.
4. Raghunandan Capital Private Limited or its associated persons should, in writing, inform  a client of the policy on Management of Conflict of Interest and how it may be accessed.
5. Intimation of an actual or potential COI should be made to a person with responsibility for the issue or area, such as the relevant management team, head of the department or key individual.
6. Staff that fail to disclose  a potential or actual  COI in accordance with this policy may be liable to disciplinary procedures.
7. Where there  is no other  way of managing a conflict, or where the measures in place do not sufficiently protect Clients’ interests, the conflict will be disclosed to allow the Client to make an informed decision on whether to continue using  our service in the situation concerned.

Policies and procedures

The Company has developed and implemented policies and procedures throughout its business to prevent or manage potential conflicts of interest. Our employees receive guidance and training in these   policies   and   procedures, and   they   are   subject   to monitoring and review processes.

Procedure to comply  with the policy

1. Every staff member must have a copy of the Policy on management of Conflicts of Interest.
2. If a potential COI arises, the transaction must first be discussed with management before entering into the transaction.
3. All new employees shall be required to declare their outside interests when they join the firm.
4. All staff maintaining personal trading accounts outside of the company is required to instruct their broker to send copy contract notes and periodic statements to the company for reconciliation purposes.
5. The company Conflict of Interest Policy is located on the website www.acml.in and  is subject to annual review.

3. Internal code of conduct governing operations

Raghunandan Capital Private Limited and  Associated Persons shall  abide  by the  Code  of Conduct contained in the Schedule II of  the  Securities   and  Exchange Board  of  India  (Stock-Brokers and  Sub- Brokers)  Regulations, 1992, as  amended, for  accomplishment of the  objectives  of the SEBI Code.

4. Standards of appropriate conduct in the performance of the activities,

Raghunandan Capital Private Limited and its Associated Persons shall adopt the following standards of appropriate conduct in the performance of the activities.

1. To place  the  client’s  interests first: Placing  the  client’s interests first is a hallmark of professionalism and  its Associated Persons to act honestly and  not place  personal gain or advantage before the client’s interests.
2. To provide business services with integrity: Integrity requires honesty and sincerity in all business matters.
3. To provide business services objectively:  Objectivity requires intellectual honesty and impartiality.
4. To be  fair  and  reasonable in  all  business relationships & to  disclose  and  manage conflicts  of interest: Fairness  requires providing clients  what  they  are  due,  owed or should expect  from  a  business relationship, and  includes honesty and  disclosure  of material conflicts  of interest. It involves managing one’s own feelings, prejudices and desires to achieve a proper balance of interests. Fairness is treating others in the same manner that you would want to be treated.
5. To   act    in    a   manner   that    demonstrates   exemplary   professional   conduct: Professionalism requires behaving with  dignity and  showing respect  and  courtesy to clients,   fellow   business  associates,  and   others    in   business-related activities, and complying with appropriate rules, regulations and business requirements.
6. To maintain the abilities,   skills and knowledge necessary to provide business services competently:
7. To protect the confidentiality of all client information: Confidentiality requires client information to be protected and maintained in such a manner that allows access only to those who are authorized.
8. To provide business services diligently: Diligence requires fulfilling business commitments in a timely   and   thorough manner, and   taking   due   care in planning, supervising and delivering business services.

5. Communication of policies, procedures and code to all concerned

This Policy on management of Conflict of Interest offers general guidance in addition to policies and procedures and is not meant to replace any of those policies or procedures

6. Implementation and Review of policy of management on Conflict of Interest

This policy  shall come into effect from  the date  of approval of the Board  of Directors of the  company for  its  implementation so  as  to  provide  necessary guidance  enabling identification, elimination or management of conflict  of interest situations and  that  the same shall be reviewed and assessed annually by the company management.

For Raghunandan Capital Private Limited 

  Sd/- Director

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