RAGHUNANDAN CAPITAL PRVIATE LIMITED (RCPL)

&

RAGHUNANDAN INDUSTRIES PRIVATE LIMITED (RIPL)

26/257-B, SULTANGANJ, NEAR ASHISH PALACE, AGRA, U.P.-282004

RMCOMPLIANCE@RMONEYINDIA.COM

Version No. : 3.01

Applicable FROM: 01/04/2014

COMPLIANCE OF PREVENTION AND MONEY LAUNDERING ACT (PMLA)

This modified policy pursuant to ‘Prevention of money Laundering Act’, 2002 (PMLA) to effectively prohibit and actively prevent the money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities or flow of illegal money or hiding money to avoid paying taxes has been duly placed and approved in the meeting of Board of Directors of the Company dated 01.05.2014 in accordance with the SEBI Circular no CIR/MIRSD/1/2014 dated 12.03.2014

This policy provides a detailed Account of the procedures and obligations to be followed to ensure compliance with issues related to KNOW YOUR CLIENT (KYC) Norms, ANTI MONEY LAUNDERING (AML), CLIENT DUE DILIGENCE (CDD) and COMBATING FINANCING OF TERRORISM (CFT). Policy specifies the need for Additional disclosures to be made by the clients to address concerns of Money Laundering and Suspicious transactions undertaken by clients and reporting to FINANCE INTELLIGENT UNIT (FIU-IND). These policies are applicable to both Branch and Head office Operations and are reviewed from time to time.

Every possible measures are taken for the effective implementation of the Policy. The measures taken are adequate, appropriate and abide by the spirit of such measures and requirements as enshrined in the PMLA to the best of our satisfaction.

Financial Intelligent Unit (FIU):

The government of India set up Financial Intelligent Unit -India (FIU) on 18th November 2004 as an independent body to report directly to the Economic Intelligence council (EIC) headed by the Finance Minister.

FIU-IND has been established as the central national agency responsible for receiving, processing, analyzing and disseminating information relating to suspect financial transaction. FIU-IND is also responsible for coordinating and stretching efforts of national and international intelligence and enforcement agencies in pursuing the global efforts against Money laundering and related Crimes.

The Prevention of Money Laundering Act, 2002 (PMLA):

The Prevention of Money Laundering Act, 2002 (PMLA) has been brought into force with effect from 1st July, 2005. Necessary Notifications / Rules under the said Act have been published in the Gazette of India on 1st July 2005 by the Department of Revenue, Ministry of Finance, and Government of India.

As per PMLA, every banking company, financial institution (which includes Chit Fund company, a co-operative bank, a housing finance institution and a non-banking financial company) and Intermediary (which includes a Depository Participants, Stock-broker, sub-broker, share transfer agent, banker to an issue, trustee to a trust deed, registrar to an issue, merchant banker, underwriter, Portfolio Manager, Investment adviser and any other intermediary associated with securities market and registered under section 12 of the Securities and Exchange Board of India Act, 1992) shall have to maintain a record of all the transactions, the nature and value of which has been prescribed in the Rules notified under the PMLA. 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 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 of suspicious transactions reporting apart from `transactions integrally connected’, `transactions remotely connected or related need to be considered.

“Suspicions Transactions” 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 the proceeds of crime; or

(b) Appears to be made in circumstances of unusual or unjustified complexity; or

(c) Appears to have no economic rationale or bonafide purpose.

4. 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 discourage and identify any money laundering or terrorist financing activities.

This policy provides to have a system in place to identify, monitor and reporting the suspected money laundering or terrorist financing transactions to law enforcing authorities. This policy is in conformity with SEBI Guidelines, CDSL and Exchanges Requirements.

Obligations of intermediaries under Prevention of Money Laundering Act, 2002 (PLMA)

• Appoint a Principal Officer who would be responsible for ensuring of provisions of PMLA
• Name, designation, address and e-mail address of such Principal officer be intimated to Office of Director – FIU, Delhi
• Adopt written procedures to implement the anti-money laundering provisions
• Communicating the policies relating to PMLA/CFT to management/staff handling accounts information, securities transactions and customer records (at branches/ department/ subsidiaries)
• The Policy to contain ; risk based approach, classification of clients as Clients of Special category (CSC), verification of names of customers in updated list of individuals and entities subject to various sanction measures of UN Security Council Committee and complying with Government order UAPA
• Co-operation with law enforcement authorities and timely disclosure of information

The Policy aims to achieve:

1. Customer acceptance policy and customer due diligence measures
2. Monitoring of transaction, its evaluation for the purpose.
3. Maintenance of records.
4. Compliance with statutory and regulatory requirements
5. Co-operation with law enforcing agencies, including the timely disclosure of information.
6. Proper training of the staff member in efficient monitoring the procedure.
7. Role of internal auditors to ensure compliance of policies, procedures and control to prevent money laundering.

Appointment of Principal Officer:

To prevent and control Money Laundering, we have appointed “Principal Officer” in terms of Money Laundering Act, 2002 and the same were intimated to FIU-DIRECTOR, Chanakyapuri, Delhi.

RIGHTS AND POWERS OF PRINCIPAL OFFICER

1. The principal officer / other appropriate officials have timely access to customer identification data and other CDD information.
2. The principal officer has access and is able to report to Senior Management his/her next reporting level or the Board of Directors.

RESPONSIBILITIES:

The Principal Officer and Alternate Officer will ensure that:

A] The Board approved AML Program is implemented effectively.

B] CDSL generated data based on set parameters is downloaded timely to enable us to analyze the data and report transactions of suspicious nature to FIU-IND directly.

C] CDSL 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] CDSL Staff are trained to address issues regarding the application of the PMLA.

E] The Staff selection and training process complies with the PMLA Policy.

F] Any other responsibilities assigned by MD & CEO or any other Official authorized by MD & CEO from time to time.

G] We are regularly updated regarding any changes / additions / modifications in PMLA provisions.

Appointment of Designated Director

To prevent and control Money Laundering, we have appointed “Designated Director” in terms of Money Laundering Act, 2002 and the same were intimated to FIU-DIRECTOR, Chanakyapuri, Delhi.

Our Designated director is responsible to ensure overall compliance with the obligations imposed under chapter IV of the Act and the Rules.

CONTENTS OF PMLA/CFT GUIDELINESS:

1. Communicating the policies relating to PMLA/CFT to management/staff handling accounts information, securities transactions and customer records (at branches/ department/ subsidiaries)
2. The above to contain ; risk based approach, classification of clients as Clients of Special category (CSC), verification of names of customers in updated list of individuals and entities subject to various sanction measures of UN Security Council Committee and complying with Government order UAPA.
3. Co-operation with law enforcement authorities and timely disclosure of information.

Risk-Based Approach to KYC

Client acceptance is a critical activity in AML compliance. Every new Client accepted by an institution provides the individual 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 imperative that institutions capture information about their customers’ background, sources of funds, business, domicile and financial products used by them and how these are delivered to them in order to properly understand their risk profile.

Encouragingly, 88 per cent of respondents reported that they are adopting a risk based approach to account opening, and hence KYC, with another 8 per cent actively considering moving towards it.

With the multitude of requirements by different regulators around the globe, specifically when entering into correspondent financial relationships, Indian financial institutions may have adopted a risk-based approach earlier than expected and before regulations mandated it. For local business of multinational financial institutions this would not be the case as they often adopt global policies and procedures, hence, they follow global best practices and standards.

As customer risk rating and KYC drives enhanced due diligence and ongoing monitoring it is critical that organizations conduct a comprehensive assessment to understand the risks associated with their business and customers. This in turn will provide a basis upon which associated policies and procedures can be developed.

Risk Assessment

The Company has 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.

The parameters of clients into Clients of Special Category (as given below) may be classified as higher risk and higher degree of due diligence and regular update of KYC profile should be performed.

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. They are good corporate / HNIs who have a respectable social and financial standing. These are the clients who make payment on time and take delivery of shares.

Category “B” clients are those who are intra-day clients or speculative clients. 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, do not have any financial status, etc.

Acceptance of Clients through Risk-Based Approach:

The clients may be of a higher or lower risk category depending on circumstances such as the customer’s background, type of business relationship or transaction etc. We should apply each of the clients due diligence measures on a risk sensitive basis. We should adopt an enhanced customer due diligence process for higher risk categories of customers. Conversely, a simplified customer due diligence process may be adopted for lower risk categories of customers. In line with the risk-based approach, we should obtain type and amount of identification information and documents necessarily dependent on the risk category of a particular customer.

Clients of Special Category (CSC):

CSC Clients include the following:

1. Non-resident clients (NRI);
2. High Net worth clients (HNI)
3. Trust, Charities, NGOs and organizations receiving donations.
4. Companies having close family shareholdings or Beneficial Ownership.
5. Politically Exposed Persons (PEP) of Foreign Origin
6. Current /Former Head of State, Current or Former Senior High profile politicians and connected persons (immediate family, close advisors and companies in which such individuals have interest or significant influence);
7. Companies offering Foreign Exchange offerings;
8. 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.
9. Non-face to face clients;
10. Clients with dubious reputation as per public information available etc.

The above mentioned list is only illustrative and we should exercise independent judgment to ascertain whether new clients should be classified as CSC or not.

We have adopted the following specific parameters, which are related to the overall ‘Client due Diligence Process’:

A. Policy for acceptance of clients

B. Procedure for identifying the clients

C. Transaction monitoring and reporting especially Suspicious Transactions Reporting (STR)

D. Risk management

E. Analyzing alerts

F. Reporting of alerts to FIU-IND

G. Reliance on third party for carrying out due diligence

H. Other Parameters

(A) Policy for acceptance of clients

We are taking following safeguards while accepting the clients:

1. We have instructed our account opening section not to open account in a fictitious / benami name or on an anonymous basis in any circumstances.
2. It is necessary to make proper checks before opening a new account so as to ensure that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations etc.
3. We have not been allowing account opening, where it is unable to apply appropriate clients due diligence measures / KYC policies i.e. it is unable to verify the identity and /or obtain documents required as per the risk categorization due to non-cooperation of the Client.
4. We have been regularly updating KYC profile of “clients of special category” defined under Money Laundering Act 2002, if any.
5. We are taking full detail of all the clients including occupational detail and financial detail.
6. We have been properly complying documentation requirement and other information in respect of different classes of clients depending on perceived risk and having regard with the requirement to the Prevention of Money Laundering Act 2002, guidelines issued by RBI and SEBI from time to time.
7. We have not been allowing any client to act on behalf of another person / entity.
8. We have been taking special caution in case of account opening of NRI, OBC, and FIIs etc.
9. Special instructions given to update on yearly Basis financial updates of all the active clients.

(B) Procedure for identifying the clients

As per code of conduct for Stock Broker in SEBI (Stock Brokers and Sub‐brokers) Regulations, 1992, SEBI Master Circular No. CIR/ISD/AML/3/2010 dated December 31, 2010 and SEBI circular CIR/MIRSD/2/2013 dated January 24, 2013, all SEBI registered market intermediaries are required to conduct due diligence on identification of Beneficial Ownership.

Accordingly the Company has formulated this Policy relating to identification of Beneficial Ownership and categorises the Beneficial ownership for this purpose as the natural person or persons who ultimately own, control or influence a client and/or persons on whose behalf a transaction is being conducted, and includes a person who exercises ultimate effective control over a legal person or arrangement.

i. For Individual Clients (Natural Persons):

Where the Client is an Individual, to check the identity of such natural person; doing In-Person Verification as per PMLA; follow KRA regulations; conduct due diligence in accordance with norms and to do such other verifications necessary to verify the real identity of client.

ii. 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, following steps be made to identify the beneficial owners of the client and take reasonable measures to verify the identity of such persons, through the following information:

• To check the identity of Juristic person, if it is an unlisted incorporated company under the provisions of Companies Act, 1956, on MCA website at mca.go.in/MCA21& to get shareholding detail of company.
• To check 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.
• In cases where there exists doubt under clause 4 (a) above 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
• Where no natural person is identified under clauses (b) or (c) above, the identity of the relevant natural person who holds the position of senior managing official.

iii. For client which is a trust:

Where the client is a trust, the company will identify the beneficial owners of the client and take reasonable measures to verify the identity of such persons, through 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.

iv. For Foreign Investors

The Company dealing with foreign investors’ viz., Foreign Institutional Investors, Sub Accounts and Qualified Foreign Investors for the purpose of identification of beneficial ownership of the client, it will follow the risk based due diligence approach as prescribed by SEBI Master Circular on AML No. CIR/ISD/AML/3/2010 dated December 31, 2010.

Also, they shall conduct ongoing client due diligence based on the risk profile and financial position of the clients as prescribed in Annexure A of SEBI Circular CIR/MIRSD/ 11 /2012 dated September 5, 2012.

Further the company will also adhere to the following while identifying the clients:

1. Maintenance of updated list of individuals / entities subject to various sanctions / measures available from the site http:www.un.org/sc/committees/1267/consolist.shtml and to regularly scan all existing accounts to ensure that no account is held by any of the entities or individuals included in the above list.

2. For customers that are natural persons, it is required to obtain sufficient identification data to verify the identity of the customer, his address/location, and also his recent photograph. For customers that are legal persons or entities, it is required to (i) verify the legal status of the legal person/ entity through proper and relevant documents (ii) verify that any person purporting to act on behalf of the legal person/entity is so authorized and identify and verify the identity of that person, (iii) understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person. Customer identification requirements in respect of a few typical cases, especially, legal persons requiring an extra element of caution.

3. In the event of matching any particulars of designated individuals/entities, we will inform the full particular of the funds, financial assets or economic resources or related services held in the form of securities, within 24 hours to the joint secretary (IS.I) Ministry of Home Affairs, at a given fax / phone number and email id and will also send the same to the email id and address of SEBI.

4. In the event of matching the details beyond doubt, we will prevent the persons from conducting any further financial transactions under intimation to the above mentioned authorities and will file STR to FIU, IND, covering all transactions.

5. The ‘Know your Client’ (KYC) policy is clearly defined and adopted under the supervision of Principal Officer.

6. We have been identifying the client by using reliable sources including documents / information, in person verification, etc.

7. We have seen each original document prior to acceptance of a copy and same be stamped “Verified with the original”. The information collected by us is enough to satisfy competent authorities (regulatory / enforcement authorities) in future that due diligence was observed by us in compliance with the Guidelines.

8. We have been noting failure by prospective client to provide satisfactory evidence of identity and same to be reported to the higher authority within the organization.

(C) Transaction monitoring and reporting especially Suspicious Transactions Reporting

Ongoing monitoring is an essential element of effective KYC procedures. We can effectively control and reduce the risk only if the companies 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 pay 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:

1. we will examine the background and the purpose of transactions which are complex or unusually large/ with patterns which appear to have no economic purpose/ which exceed the limits specified for the relevant class of client accounts, and record the findings in writing; make available such findings, records and related documents to auditors, SEBI, Stock Exchanges, FIUIND, other relevant authorities during audit, inspection or as and when required.
2. we will submit cash Transactions Report (CTR) wherever applicable, for each month by 15^th of the succeeding month to FIU-IND
3. We will submit Suspicious Transaction Report (STR) within 7 days of arriving at a conclusion that any transaction are of suspicious nature to FIU-IND
4. To preserve records involving CTR/STR for ten years as required under PMLA, 2002
5. We have been taking close surveillance, where transaction amounting to Rs. 10 Lacs or more.
6. We have not been allowing any cash transaction with client.
7. We regularly monitor the transactions for generation of alerts for identification of suspicious transactions.

The Principal Officer would act as a central reference point in facilitating onward reporting of suspicious transactions and for playing an active role in the identification and assessment of potentially suspicious transactions.

(D) Risk Management

The Board of Directors of the company ensure that an effective KYC programme is put in place by establishing appropriate procedures and ensuring their effective implementation covering proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibilities are explicitly allocated within the company for ensuring that the Company’s policies and procedures are implemented effectively. The company, in consultation with boards, has decided to devise procedures for creating Risk Profiles of the existing and new customers and apply various Anti Money Laundering measures keeping in view the risks involved in a transaction, account or business relationship.

As The internal audit and compliance functions have an important role in evaluating and ensuring adherence to the KYC policies and procedures, the compliance function should provide an independent evaluation of the Company’s own policies and procedures, including legal and regulatory requirements. The company will appoint and conduct Concurrent/ Internal Audits on specific intervals that will specifically check and verify the application of KYC procedures at the branches and will comment on the lapses observed in this regard. The compliance in this regard may be put up before the Board on quarterly intervals.

The company will conduct an ongoing employee training programme so that all the staff are adequately trained in KYC procedures. Training requirements should have different focuses for frontline staff, compliance staff and staff dealing with new clients. It is crucial that all those concerned fully understand the rationale behind the KYC policies and implement them consistently

Implementation of KYC procedures requires the company to demand certain information from client which may be of personal in nature or which has hitherto never been called for. This can sometimes lead to a lot of questioning by the client as to the motive and purpose of collecting such information. There is, therefore, the company will educate, from time to time, the customer of the objectives of the KYC programme.

(E) RECORD KEEPING:

For the purpose of the record keeping provision, we should ensure compliance with the record keeping requirements contained in the SEBI Act, 1992, Rules and Regulations made there-under, PLM act, 2002 as well as other relevant legislation, Rules, Regulations, Exchange Bye-laws and Circulars. Records to be maintained should be sufficient to permit reconstruction of individual transactions (including the amounts and type of currencies involved, if any) so as to provide, if necessary, evidence for prosecution of criminal behavior. Should there be any suspected drug related or other laundered money or terrorist property, the competent investigating authorities would need to trace through the audit trail for reconstructing financial profile of the suspect’s account. To enable this reconstruction, Organization should retain the following information for the accounts of their customers in order to maintain a satisfactory audit trail.

1. The beneficial owner of the account;
2. The volume of the funds flowing through the account; and
3. For selected transactions.
4. The origin of the funds;
5. The form in which the funds were offered or withdrawn, e.g. cash, cheques etc;
6. The identity of the person undertaking the transaction;
7. The destination of the funds;
8. The form of instruction and authority.

Organization should ensure that all client and transaction records and information are made available on a timely basis to the competent investigating authorities.

(F) MAINTENANCE / RETENTION OF THE RECORDS:

Following Document Retention Terms should be observed:

1. 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.
2. 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.
3. Records shall be maintained in hard and soft copies.
4. All necessary records on transactions, both domestic and international, should be maintained and preserved for a period of five years from the date of transaction between the client and intermediary.
5. Records on customer identification (e.g., copies or records of official identification documents like passports, identity cards, driving licenses or similar documents) as well as account files and business correspondence for a period of five years after the business relationship between a client and company have ended or the account has been closed, whichever is later.
6. 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.
7. 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.

(G) MONITORING OF TRANSACTIONS:

1. Regular monitoring of transactions is required for ensuring effectiveness of the Anti-Money Laundering procedures.
2. Special attention required to all complex, unusually large transactions / patterns which appear to have no economic purpose.
3. Internal threshold limits to specify for each class of client’s accounts and pay special attention to the transaction, which exceeds these limits.
4. Should ensure that the records of transaction is preserved and maintained in terms of the PMLA 2002 and that transaction of suspicious nature or any other transaction notified under section 12 of the act is reported to the appropriate authority.
5. Suspicious transactions should also be regularly reported to the higher authorities / head of the department.

Further the Compliance Department should randomly examine select transaction undertaken by clients to comment on their nature i.e. whether they are in the suspicious transactions or not.

(H) SUSPICIOUS TRANSACTION MONITORING & REPORTING:

Whether a particular transaction is suspicious or not will depend upon the background, details of the transactions and other facts and circumstances. Followings are the circumstances, which may be in the nature of suspicious transactions:-

1. Clients whose identify verification seems difficult or clients appears to be not co-operating.
2. Asset management services for clients where the source of the funds is not clear or not in keeping with client’s apparent standing / business activity; Clients in high-risk jurisdictions or clients introduced by banks or affiliates or other clients based in high risk jurisdictions;
3. Substantial increases in business without apparent cause.
4. Unusually large cash deposits made by an individual or business;
5. Clients transferring large sums of money to or from overseas locations with instructions for payment in cash;
6. Transfer of investment proceeds to apparently unrelated third parties;
7. Unusual transactions by “Client of special category (CSCs)” and businesses undertaken by shall corporations, offshore banks / financial services, business reported to be in the nature of export-import of small items.

• Submission of Suspicious Transactions Reports :

Submission of such reports shall be made within the time limit prescribed as follows:-

• Suspicious transaction reports shall be submitted in writing or by fax or electronic mail within three working days from the date of occurrence of the transactions.
• Notifications issued by SEBI require STR to be reported within 7 working days of establishment of suspicion at the level of Principal Officer

(F) Reporting of alerts/STRs to FIU-IND

1. All the suspicious transaction Alerts generated will be reported to FIU-IND, if required.

(G) 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) determination of whether the client is acting on behalf of a beneficial owner, identification of the beneficial owner and verification of the identity of the beneficial owner.

(H) Other parameters

• Retention of Records

We have observed the following document retention:

1. We are bound to maintain all necessary records, if any, on transactions, both domestic and international at least for the minimum period prescribed under the relevant Act (PMLA, 2002 as well SEBI Act, 1992) and other legislations, Regulations or exchange bye-laws or circulars.

1. We are also bound to keep records, if any, on customer identification (e.g. copies or records of official identification documents like passports, identity cards, driving licenses or similar documents), account files and business correspondence for the period of 5 years.

• Training of staff/Employees

The company has adequately trained staff in AML and CFT (Combating Financing of Terrorism) procedures.

The Company shall have an ongoing employee-training programmed so that the their staff are adequately trained in Anti Money Laundering and Combating Financing of Terrorism procedure.

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

• Employees Hiring

The Company shall have adequate screening procedures in place to ensure high standard when hiring employees. It shall identify the key positions within the Company structure having regard to the risk of money laundering and terrorist financing.

• Investor’ Education

The company shall prepare this specific literature so that the clients/sub-brokers/Authorised Person can be educated on the objectives of the Anti-Money Laundering (AML) / Combating Financing of Terrorism (CFT) programme.

Review of PMLA/CFT Procedures

The policy shall be reviewed from time to time as and when required by the Management and also implement the change after any change 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.

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.

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.

Raghunandan Money had outsourced research from CFR & Advisory whose proprietor MrPronod Kumar Bharatiya (Email ID :research.cfra01@gmail.com) is a SEBI registered Research Analyst with registration number INH100000486.

Raghunandan Money, 26/257 B , Near Ashish Palace, Sultan Ganj , Agra – 282004, Tel : 91+562+4266600, Fax : 91+562+2526550, Email: askus@rmoneyindia.com.

Disclosure:

I, Pronod Kumar Bharatiya is the owner/proprietor of Centre for Financial Research and Advisory (CFR & Advisory, henceforth), having its registered office at 26/257B, Sultanganj, Near Ashish Place, Agra – 282004 and is a registered Research Analyst with SEBI Regn No. : INH100000486and is regulated by Securities and Exchange Board of India, authors and the names subscribed to thereport(s) & call(s), hereby certify that all of the views expressed in the research report(s) & call(s) accurately reflect our views about the subject issuer(s) or securities. I also certify that no part of our compensation was, is, or will be directly or indirectly related to the specific recommendation(s) or view(s) in thereport(s) & call(s).

Research Analyst or his/her relative or Raghunandan Money or its associates, does not have any financial interest in the subject company. Also Research Analyst or his relative or Raghunandan Money or its Associate do not have beneficial ownership of 1% or more in the subject company at the end of the month immediately preceding the date of publication of the Research report(s) & call(s). Further Research Analyst or his relative or Raghunandan Money or its associates, does not have any material conflict of interest.

Any holding in stock – No

Disclaimer:

Thereport(s) & call(s) has been prepared by CFR & Advisory for and on behalf of Raghunandan Money and is meant for sole use by the recipient and not for circulation. The information and opinions contained herein have been compiled or arrived at, based upon information obtained in good faith from sources believed to be reliable. Such information has not been independently verified and no guaranty, representation of warranty, express or implied, is made as to its accuracy, completeness or correctness. All such information and opinions are subject to change without notice.

This document is for information purposes only. Descriptions of any company or companies or their securities mentioned herein are not intended to be complete and this document is not, and should not be construed as an offer or solicitation of an offer, to buy or sell any securities or other financial instruments.

Thereport(s) & call(s)are not directed to, or intended for display, downloading, printing, reproducing or for distribution to or use by, any person or entity who is a citizen or resident or located in any locality, state, country or other jurisdiction where such distribution, publication, reproduction, availability or use would be contrary to law or regulation or what would subject CFR & Advisory, Raghunandan Money or its affiliates to any registration or licensing requirement within such jurisdiction.

CFR & Advisory, Raghunandan Money and its affiliated company(ies), their directors and employees may;

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(b) be engaged in any other transaction involving such securities and earn brokerage or other compensation or act as a market maker in the financial instruments of the company(ies) discussed herein or act as an advisor or lender/borrower to such company(ies) or may have any other potential conflict of interests with respect to any recommendation and other related information and opinions.

CFR & Advisory, Raghunandan Money, its directors, analysts or employees do not take any responsibility, financial or otherwise, of the losses or the damages sustained due to the investments made or any action taken on basis of thereport(s) & call(s), including but not restricted to, fluctuation in the prices of shares and bonds, changes in the currency rates, diminution in the NAVs, reduction in the dividend or income, etc.

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