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 Pvt Ltd being the Member of National Stock Exchange of India Ltd., (NSE) having SEBI Registration Nos. INB / INF / INE 231317638 in Capital Market, Derivatives and Currency Derivatives Segment, Member of Bombay Stock Exchange Ltd. (BSE) having SEBI Registration No. INB / INF 011317634 in Capital Market and Derivatives Segment, Member of MCX Stock Exchange Ltd (MCX-Sx) having SEBI Registration No. INE 261317638 in Currency Derivatives Segment and Member of United Stock Exchange of India Ltd (USE) having SEBI Registration No. INE 271317633 in Currency Derivatives Segment.

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 Pvt Ltd 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.

PMLA POLICY

Of the Group comprising of
Raghunandan Capital (P) Ltd.
Being the Member of NSEIL vide SEBI Regn No INB/INF/INE 231317638,
Being the Member of BSE Ltd vide SEBI Regn No INB/INF/INE 011317634,
& Depository Participant of CDSL vide SEBI Regn No IN-DP-213-2016
And
Raghunandan Industries (P) Ltd.
Being the Member of MCX Ltd vide SEBI Regn No INZ000024832,
Being the Member of NCDEX vide SEBI Regn No INZ000024832,
& Being the Member of ICEX vide SEBI Regn No INZ000024832

Policy Version No. 3.02
Date of Last Policy Review: 01st October, 2016

POLICY FRAMEWORK FOR IMPLEMENTATION OF THE PROVISIONS OF
PREVENTION AND MONEY LAUNDERING ACT (PMLA) 2002
Introduction
The Prevention of Money Laundering Act, 2002 (PMLA) came in force with effect
from 1st July 2005.
As per the provisions of the PMLA, each market intermediary (Reporting Entity)
(which includes a stockbroker, sub-broker, share transfer agent, banker to an
issue, trustee to a trust deed, registrar to an issue, asset management company,
depositary participant, merchant banker, underwriter, portfolio manager,
investment adviser and any other intermediary associated with the securities
market and registered under Section 12 of the Securities and Exchange Board of
India Act, 1992 (SEBI Act) shall have to adhere to client account opening
procedures and maintain records of such “transactions” as prescribed by the
PMLA and Rules notified there under.
Obligations of a “Reporting Entity” includes:-
a. to maintain a record of all transactions covered as per the nature and value of
which may be prescribed, in such manner as to enable it to reconstruct
individual transactions
b. furnish to the Director (FIU) within such time as may be prescribed information
relating to such transactions, whether attempted or executed, the nature and
value of which may be prescribed
c. verify the identity of its clients in such manner and subject to such conditions
as may be prescribed
d. identify the beneficial owner, if any, of such of its clients, as may be
prescribed
e. maintain record of documents evidencing identity of its clients and beneficial
owners, account files and business correspondence relating to its clients and
information related to transactions for specified period.
For the purpose of PMLA, transactions include:
1. all cash transactions of the value of more than Rs.10 Lakhs or its equivalent in
foreign currency.
2. all series of cash transactions integrally connected to each other, which have
been valued below Rs.10 Lakhs or its equivalent in foreign currency, such
series of transactions within one calendar month.
3. all suspicious transactions (remotely / integrally connected or related),
whether or not made in cash and including, inter-alia, credits or debits into
from any non-monetary account such as Demat account, security account
maintained by the registered intermediary.
For the purpose “Suspicions Transaction” means a transaction whether or not
made in cash which to a person acting in good faith:–
a. gives rise to a reasonable ground of suspicion that it may involve proceeds of
an offence specified in the Schedule to the Act, regardless of the value
involved; or
b. appears to be made in circumstances of unusual or unjustified complexity; or
c. appears to have no economic rationale or bonafide purpose; or
d. gives rise to a reasonable ground of suspicion that it may involve
financing of the activities relating to terrorism;
The Anti-Money Laundering Guidelines provides a general background on the
subjects of money laundering and terrorist financing in India and provides
guidance on the practical implications of the PMLA. The PMLA Guidelines sets
out the steps that a registered intermediary and any of its representatives, need
to implement to identify and discourage any “Money Laundering” (ML) or
“Terrorist Financing” activities.
SEBI has issued various directives vide circulars, from time to time, covering
issues related to Know Your Client (KYC) norms, Anti- Money Laundering (AML),
Client Due Diligence (CDD) and Combating Financing of Terrorism (CFT). The
directives lay down the minimum requirements and it is emphasized that the
intermediaries may, according to their requirements, specify additional
disclosures to be made by clients to address concerns of money laundering and
suspicious transactions undertaken by clients.
While it is recognized that a “one-size-fits-all” approach may not be appropriate
for the securities industry in India, each registered intermediary is required to
implement suggested measures and procedures considering the specific nature
of its business, organizational structure, type of clients and transactions, etc. to
ensure that they are effectively applied.
Global measures taken to combat drug trafficking, terrorism and other organized
and serious crimes have all emphasized the need for financial institutions,
including securities market intermediaries, to establish internal procedures that
effectively serve to prevent and impede money laundering and terrorist financing.
To be in compliance with these obligations, the senior management of a
registered intermediary shall be fully committed to establishing appropriate
policies and procedures for the prevention of ML and TF and ensuring their
effectiveness and compliance with all relevant legal and regulatory requirements.
The obligations of an intermediary under Prevention of Money Laundering Act,
2002 (PLMA) includes:-
a. issuance and adoption of written policy statement, on a group basis (wherever
applicable), for dealing with the risk of MF and TF within the framework of
current statutory and regulatory requirements,
b. ensuring that these directives and contents of policy is understood by all staff
members,
c. regular review of policy and procedures of prevention of ML & TF and to
ensure that such reviews are conducted by the person other that the one
framing the policy,
d. adoption of client acceptance policies and procedures which are sensitive to
the risk of MF & TF,
e. undertaking client due diligence measures to an extent that is sensitive to the
risk of ML & TF
f. compliance with relevant statutory and regulatory requirements
g. have system in place for identification, monitoring and reporting of suspected
ML and TF transactions to concerned authorities
h. co-operation with relevant law enforcement authorities and timely disclosure
of information
i. defining the role of internal auditors to ensure compliance of policies,
procedures and control to prevent money laundering.
Accordingly, we have drafted this written policy framework (hereinafter called as
“PMLA Policy”) for our whole group (consisting of Raghunandan Capital (P) Ltd.
having SEBI Regn Nos. in NSE-INB/INF/INE 231317638, In BSE- INB/INF/INE
011317634 and in Raghunandan Industries (P) Ltd. having SEBI Regn Nos.
MCX-INZ000024832, In NCDEX- INZ000024832, In ICEX- INZ000024832 ) for
policy which aims to have a system in place to identify, monitor and reporting the
suspected money laundering or terrorist financing transactions to law enforcing
authorities within the framework of current statutory and regulatory requirements.
All concerned are hereby advised to ensure that every possible measures are
taken for the effective implementation of this Policy and that the measures taken
are adequate, appropriate and abide by the spirit and requirements as enshrined
in the PMLA.
Detailed PMLA Policy Framework
1. Principal Officer:
To ensure effective discharge of our legal obligations to report suspicious
transactions to the authorities, we hereby appoint the “Principal Officer” who
would act as a central reference point for the identification and assessment of
potentially suspicious transactions and in facilitating onward reporting of
suspicious transactions to FIU.
Complete Details of Principle are as given below:-
Name: Rahil Uddin
Designation: Assistant Manager
Contact No: 9958008163
Email: rahil.uddin@rmoneyindia.com
Rights and Obligations of Principle Officer:
a. The principal office shall have all time access to customer identification
data and other CDD information.
b. The principal officer shall have complete independence and authority to
access and is able to report to Senior Management or his / her next
reporting level or the Board of Directors.
Responsibilities:
The Principal Officer shall ensure that:
a. the Board approved PMLA Policy framework is implemented effectively.
b. systems generated data based on set parameters is regularly and
promptly downloaded to analyze, identify and report transactions of
suspicious nature to FIU-IND directly
c. group responds promptly to any request for information, including KYC
related information maintained by us, made by the regulators, FIU-IND and
other statutory authorities.
d. group`s staff members and associates are trained to address issues
related to the application of the PMLA.
e. the staff selection and training process complies with the PMLA Policy.
f. group and all concerned staff is regularly updated regarding any changes /
additions / modifications in PMLA provisions.
2. Appointment of Designated Director
For ensuring overall supervision and compliance with the obligations imposed
under chapter IV of the Act and the Rules the group has appointed the
“Designated Director”. The details of the designated Director are as given
below:-
Name: Mr. Saurabh Mittal
Designation: Director
Contact No: 9897036767
Email: Saurabh.mittal@rmoneyindia.com
3. Client Due Diligence Measures (CDD Measures)
The CDD measures comprise the following:
a. Obtain 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.
b. Verify the client’s identity using reliable, independent source documents,
data or information;
c. 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;
d. 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);
e. Understand the ownership and control structure of the client;
f. 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
g. All documents, data or information of all clients and beneficial owners
collected under the CDD process shall be periodically updated.
The beneficial owner for this purpose mean, the natural person or persons
who ultimately own, control or influence a client and/or persons on whose
behalf a transaction is being conducted. It also incorporates those persons
who exercise ultimate effective control over a legal person or arrangement.
Suggestive measures for identification of beneficial ownership is as given
below:-
i.) For clients other than individuals or trusts:
Where the client is a person other than an individual or trust, viz.,
company, partnership or unincorporated association/body of
individuals, identification of beneficial owners of the client may be
done by applying following measures namely;
Ascertain the identity of the natural person, who, whether acting
alone or together, or through one or more juridical person,
exercises control through ownership or who ultimately has a
controlling ownership interest.
Explanation: Controlling ownership interest means ownership of /
entitlement to:
 more than 25% of shares or capital or profits of the
juridical person, where the juridical person is a company;
 more than 15% of the capital or profits of the juridical
person, where the juridical person is a partnership; or
 more than 15% of the property or capital or profits of the
juridical person, where the juridical person is an
unincorporated association or body of individuals.
In cases where there exists doubt as to whether the person with
the controlling ownership interest is the beneficial owner or
where no natural person exerts control through ownership
interests, the identity of the natural person exercising control
over the juridical person through other means.
Explanation: Control through other means can be exercised
through voting rights, agreement, arrangements or in any other
manner.
Where no natural person is identified under clauses mentioned
above, the identity of the relevant natural person who holds the
position of senior managing official.
ii.) For client which is a trust:
Where the client is a trust, the beneficial ownership of the client
shall be identifying by taking reasonable measures to verify the
identity of the settler of the trust, the trustee, the protector, the
beneficiaries with 15% or more interest in the trust and any other
natural person exercising ultimate effective control over the trust
through a chain of control or ownership.
iii.) Exemption in case of listed companies:
Where the client or the owner of the controlling interest is a
company listed on a stock exchange, or is a majority-owned
subsidiary of such a company, it is not necessary to identify and
verify the identity of any shareholder or beneficial owner of such
companies.
Reliance on third party for carrying out due diligence
We may rely on a third party for the purpose of
a. identification and verification of the identity of a client and
b. Where the client is acting on behalf of a beneficial owner, identification of
the beneficial owner and verification of the identity of the beneficial owner.
Provided such 3rd party is regulated, supervised or monitored for and have
measures in place for CDD and KRA is one such example of the same.
However as a registered intermediary we shall be ultimately responsible for
CDD and undertaking enhanced due diligence measures
4. Policy for acceptance of Clients
Our client acceptance policies and procedures aims to identify the types of
clients that are likely to pose a higher than average risk of ML or TF so that
we will be in a better position to apply client due diligence on a risk sensitive
basis depending on the type of client business relationship or transactions.
In nutshell the following safeguards are to be followed while accepting the
clients namely;
a. No account is opened in a fictitious / benami name or on an anonymous
basis.
b. Each client shall be classified into low or medium or high risk categories
depending upon the risk perception.
Such risk categorization may be arrived considering various factors of risk
perception of the client having regard to:-
– clients’ location (registered office address, correspondence
addresses and other addresses if applicable),
– nature of business activity, trading turnover etc. and
– manner of making payment for transactions undertaken.
Clients of Special Category (CSC) (as defined later in this policy) may, if
necessary, be classified even higher. Such clients require higher degree of
due diligence and regular update of Know Your Client (KYC) profile.
c. Documentation requirements and other information to be collected in
respect of different classes of clients depending on the perceived risk and
having regard to the requirements of Rule 9 of the PML Rules, Directives
and Circulars issued by SEBI from time to time.
d. We must obtain documentary evidence of each KYC information provided
by the client and verify each such supporting document with originals prior
to acceptance of a copy and same be stamped “Verified with the original”
and each client must be met in person before registration.
The information collected by us should be enough to satisfy competent
authorities (regulatory / enforcement authorities) in future that due
diligence was observed by us in compliance with the Guidelines.
A complete identification record of person doing the In-person verification
and verification of documents must be kept in readily available manner.
e. We should not open an account where we are unable to apply appropriate
CDD measures / KYC policies. This shall be applicable in cases where it is
not possible to ascertain the identity of the client, or the information
provided by the client is suspected to be non-genuine, or there is
perceived non co-operation of the client in providing full and complete
information.
We shall not continue to do business with such a person and file a
suspicious activity report. We shall also evaluate whether there is
suspicious any trading in determining whether to freeze or close the
account. We shall be cautious to ensure that we do not return securities or
money that may be from suspicious trades.
Further, we shall consult the relevant authorities in determining what
action we shall take when we suspects suspicious trading activity.
f. We shall ensure that in case of individual client only the client himself/
herself be allowed to transact on his/her own behalf. A person may be
allowed to deal on behalf of his / her spouse, dependent children or
dependent parents provided a written authorization is obtained from
concerned family member.
In case of non-individual clients only the person(s) having appropriate
written authorization are allowed to deal for and on behalf of the client.
In all the cases, we must obtain the identification documents of the person
so authorized to deal on behalf of the client and adequate verification of
person’s authority to act on behalf of the client shall also be carried out.
The authorization letter should specify the manner in which the account
shall be operated, transaction limits for the operation, additional authority
(if any) required for transactions exceeding a specified quantity/value.
g. Before activating any account, we must ensure that the identity of the
client does not match with any person having known criminal background
or is not banned in any other manner, whether in terms of criminal or civil
proceedings by any enforcement agency worldwide.
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.
h. The CDD process shall necessarily be revisited when there are suspicions
of money laundering or financing of terrorism (ML/FT).
For the purpose of above and elsewhere used in this policy framework,
Clients of Special Category (CSC) shall include:-
i.) Non-resident clients
ii.) High net-worth clients unless known to Senior Management or
introduced by a known source,
iii.) Trust, Charities, Non-Governmental Organizations (NGOs) and
organizations receiving donations
iv.) Companies having close family shareholdings or beneficial
ownership
v.) 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.
vi.) 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- gafi.org), shall also independently access
and consider other publicly available information.
viii.) Non face to face clients
ix.) 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.
5. Risk-Based Approach to KYC
Client acceptance is a critical activity in AML compliance. Registering any
client means providing such client with an entry point to local and international
financial systems. Client acceptance, thus, becomes the first step in
controlling money laundering and terrorist financing.
Regulatory guidelines stipulate that a sound KYC program should determine
the true identity and existence of the customer and the risk associated with
the customer. It is therefore imperative that we capture information about their
background, sources of funds, nature and type of business, domicile and
financial products used by them and how these are delivered to them in order
to properly understand their risk profile.
It is generally 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. 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 we shall obtain necessarily depend on the
risk category of a particular client and for this purpose clients may be
classified into following categories namely;-
Category – A: Low Risk
Category – B: Medium Risk
Category – C: High Risk, should be classified as
Category “A” clients are those pose low or nil risk. These clients have a
respectable and verifiable social and financial standing. Their KYC
Information and financial details is easily verifiable.
Category “B” clients are those who mostly deals on intra-day basis or on
speculative basis. These are the clients who maintain running account with
the Company.
Category “C” clients are those who have defaulted in the past, have
suspicious background or the clients identified as CSC.
Any business relationship with “High Risk Clients” including clients
identified as CSC must not be commenced unless approved by Senior
Management Officials.
As customer risk rating and KYC drives enhanced due diligence and ongoing
monitoring it is critical that we conduct an ongoing comprehensive
assessment to understand the risks associated with our business and
customers and necessary modifications and improvements in associated
Client acceptance and Due Diligence Policies and Procedures.
Risk Assessment
We have formulated a periodic risk assessment mechanism to identify money
laundering and terrorist financing risk assess and take effective measures to
mitigate them with respect to our clients, countries or geographical areas,
nature and volume of transactions, payment methods used by our clients, etc.
Our risk assessment process consider all the relevant factors before
determining the level of overall risk and the appropriate level and type of
mitigation to be applied and assessment is documented and updated regularly
and made available to competent authorities and self-regulating bodies, as
and when required.
6. Transaction based Monitoring and Identification of Suspicious
Transactions
Ongoing monitoring is an essential element of effective KYC procedures. We
can effectively control and reduce the risk only if we have an understanding of
the normal and reasonable activity of the client so that they have the means of
identifying transactions that fall outside the regular pattern of activity.
However, the extent of monitoring will depend on the risk sensitivity of the
account.
Special attention is required to be given to all complex, unusually large
transactions and all unusual patterns which have no apparent economic or
visible lawful purpose.
For the purpose of monitoring of transaction under PMLA following should be
taken care of:
a. examine the background and the purpose of transactions which are
complex or unusually large/ with patterns which appear to have no
economic purpose
b. transactions which exceed the limits specified for the relevant class of
client accounts
c. understanding of normal activity in client account to identify deviations and
substantial increase in business without any apparent cause
d. clients transferring large sums of money to/from overseas locations
e. attempted transfer of proceeds to unrelated 3rd parties
f. transactions of clients based in high risk jurisdictions
g. Unusual transactions by CSCs and businesses undertaken by offshore
banks / financial services, businesses reported to be in the nature of
export- import of small items
h. Random examination of a selection of transaction to comment on their
nature
Broad category of triggers that will require the complete analysis of
transaction may include:-
a. Transactions involving Artificial Volume Creation / High Value Deals /
Synchronized Trades
b. client’s disproportionate volume with respect to his last known financial
details
c. scrip concentration-concentrated position in particular scrips which have
un usual price or volumes
d. high value off market transfer instructions
e. high value transactions in a new/dormant account
f. frequent small quantity transactions in an account
g. transaction undertaken by client with respect to whom alerts raised by
employees / media reports / Enforcement Agency etc.
h. transactions undertaken by customers for whom there are adverse media
reports about criminal activities/terrorist activities/terrorist financing
activities
i. transaction undertaken by customers who offered false/forged
identification documents / address found to be wrong
Findings of transaction analysis must be recorded in writing, as the same
along with records and related documents may required to be provided to
auditors, SEBI, Stock Exchanges, FIUIND, other relevant authorities as and
when asked for.
7. Reporting of Suspicious Transactions
The Principal Officer would act as a central reference point in playing an
active role in the identification and assessment of potentially suspicious
transactions and facilitating onward reporting of suspicious transactions.
Accordingly, any potential suspicious transaction shall immediately be notified
to Principle Officer which may be a detailed report with specific reference to
the clients, transactions and the nature / reason of suspicion and for this
purpose transactions abandoned or aborted by clients on being asked to give
some details or to provide documents are also to be reported.
We must ensure continuity in dealing with the reported client as normal until
told otherwise and the client not be told of the report/suspicion i.e. group
officials and employees shall be prohibited from “Tipping off” the fact that a
STR or related information is being reported or provided to the FIU-IND.
The Principal Officer shall examine the transaction in details and if reaches to
the conclusion that the notified transaction is “Suspicious” shall report the
same to Financial Intelligence Unit (FIU) within 7 days from the date of
arriving at such conclusion by filing the Suspicion Transaction Report (STR).
It is clarified that the STR must be filed irrespective of the amount of
transaction and/or the threshold limit, if there are reasonable grounds to
believe that the transactions involve proceeds of crime.
8. Record Keeping
We are required to 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.
To enable this reconstruction, we need to retain the following information:-
a. the nature of transaction
b. the amount of transaction and the currency in which same was
denominated
c. the date on which the transaction was conducted and
d. the parties to the transaction
We shall ensure maintaining proper record of transactions namely;-
a. all cash transactions of the value of more than rupees ten lakh or its
equivalent in foreign currency;
b. 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;
c. 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;
d. all suspicious transactions whether or not made in cash and by way of as
mentioned in the Rules
Records to be maintained in a way that all client and transaction records and
information are available on a timely basis to the competent investigating
authorities.
9. Retention of Records
Following Document Retention Terms should be observed:
a. All necessary records on transactions, both domestic and international,
should be maintained at least for the minimum period of FIVE YEARS (5)
from the date of cessation of the transaction.
b. 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.
c. In situations where the records relate to on-going investigation or
transactions, which have been the subject of a suspicious transaction
reporting, they should be retained until it is confirmed that the case has
been closed.
d. All necessary records of information related to transactions, whether
attempted or executed, which are reported to the Director, FIU-IND, as
required under Rules 7 & 8 of the PML Rules, shall be maintained and
preserved for a period of five years from the date of the transaction
between the client and the intermediary.
Records may be maintained in both hard and / or soft copies.
10. Training of staff / Employees
All the staff members involved in front office dealings, back office, KYC &
Compliances, Risk Management or any kind of client dealings need to be
adequately trained in AML and CFT (Combating Financing of Terrorism)
procedures. They should fully understand the rationale behind these
directives, obligations and requirements, implement them consistently and are
sensitive to the risks of our systems being misused by unscrupulous
elements.
Accordingly, we have an ongoing employee-training programme (in-house as
well as sending employees for attending of independent training workshops)
so that the concerned staff are adequately trained in AML and CFT
procedures.
Further, the Principle Officer is authorized to ensure that all the concerned
staff is well versed with latest modifications in the PMLA policy framework and
is adequately sensitized to the risks of ML & TF.
11. Employees Hiring
We have adequate screening procedures in place to ensure high standard
when hiring employees. We have identified the key positions within the
Company structure having regard to the risk of money laundering and terrorist
financing.
The HR Department is instructed to verify the identity, cross check all the
references, family background and should take adequate safeguards to
establish the authenticity and genuineness of the persons before recruiting.
The department should obtain the following documents:
1 Photographs
2 Proof of address
3 Identity proof
4 Proof of Educational Qualification
5 Proof of Bank Account Details
12. Investor Education
Implementation of AML/CFT measures requires us to demand certain
information from investors which may be of personal nature or which have
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 clients with regard to the motive and
purpose of collecting such information. We, therefore need to sensitize
prospective client that these requirements emanating from AML and CFT
framework.
This may either be done by preparing specific literature or by educating the
clients / sub-brokers / Authorised Person on the objectives of the Anti-Money
Laundering (AML) / Combating Financing of Terrorism (CFT) programme.
13. Review of PMLA/CFT Procedures
The policy shall be reviewed periodically so as to incorporate the latest
change(s) in the Anti Money Laundering Act 2002 or change in any other act,
bye-lows, rules, regulations of SEBI, CBI or in any statutory and regulatory
government department related to or affect to this.
Further the review of this policy framework shall be undertaken by the person
other than the one who has framed this policy.
14. Procedure for freezing of funds, financial assets or economic resources
or related services
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.
Accordingly, we need 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.

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.

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